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Sevilla v. Ross

U.S. District Court, District of South Carolina · D.S.C. · South Carolina bar guidance

Pro-se party

Conduct

Pro se parents filed 80+ motions with shotgun pleadings; court footnoted hallmarks of AI-generated or internet-sourced content.

Consequence

All pending motions denied without prejudice. Filing fee and Third Amended Complaint required. No monetary sanction.

Lesson

Volume of motion practice itself can trigger an AI-screening footnote, separate from any specific fabricated citation.

Other

Verified May 8, 2026

Citation
Sevilla v. Ross, No. 3:25-cv-03528-JDA-SVH (D.S.C. Dec. 31, 2025) (Austin, J.)
Decided
December 31, 2025

Summary

Tommy Sevilla and Melodie Sevilla, pro se plaintiffs purporting to represent themselves and their minor children, filed a civil rights action against Lexington-Richland School District Five, Dr. Akil E. Ross, Sr., and numerous other defendants concerning alleged abuse-related conduct during a football practice in June 2024 and related school district responses. The plaintiffs filed dozens of motions over the course of the case (more than 80 by year-end 2025), many of which the court characterized as "shotgun pleadings" lacking clarity about which defendants faced which claims. District Judge Jacquelyn D. Austin's December 31, 2025 omnibus order denied roughly 80+ pending motions without prejudice and noted in a footnote that "Plaintiffs' filings have many hallmarks of motions created using artificial intelligence or found on the internet."

AI tool:
Generative AI implied; the order's footnote describes "hallmarks of motions created using artificial intelligence or found on the internet"
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

All pending motions denied without prejudice. Plaintiffs ordered to pay the $405 filing fee by January 9, 2026 and to file a Third Amended Complaint within ten days of payment. Filing fee was paid on January 12, 2026 (the case was briefly dismissed but reopened two days later when the fee was confirmed). The court warned of potential sanctions but imposed no monetary penalty. As of May 2026 the case remains active with extended service deadlines.

Why does Sevilla v. Ross matter for law firms using AI?

Sevilla v. Ross is one of two D.S.C. AI-citation orders catalogued in this collection from late 2025 (the other is Cherleatha B. v. Bisignano, decided December 29, 2025). The Austin order is procedurally distinctive: rather than identifying specific fabricated citations as in most catalogued cases, the court treats the volume and pattern of pro se filings (80+ motions over eight months, shotgun pleadings, indistinguishable claims-to-defendants mappings) as the AI flag. The “hallmarks of motions created using artificial intelligence or found on the internet” footnote frames AI-generated content and internet-sourced template motions as functionally equivalent for purposes of the omnibus disposition. The case is also unusual in that it remains procedurally alive (the fee was paid; the Third Amended Complaint window has been extended), so the AI-citation observation operates as a forward-looking pleading-quality warning rather than a final sanctions event. Cross-reference: Cherleatha B. v. Bisignano (D.S.C. Dec. 29, 2025) (Lydon, J.); Jeter v. Adusa Transportation LLC (D.S.C. Dec. 15, 2025) (Brown, M.J.).

Implications for your firm

Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.

  • When opposing a high-volume pro se docket (here, 80+ motions over eight months), prepare for the court to characterize the filings as shotgun pleadings or internet-templated; identifying the AI or template pattern in the responsive briefing helps the court justify a denial-as-moot disposition rather than ruling on each motion.
  • Document the firm's protocol for naming the 'shotgun pleading' or 'hallmarks of AI' framing as a defense theory; the Austin order treats these descriptors as functionally equivalent for purposes of the omnibus denial.
  • Train associates that pro se plaintiffs purporting to represent minor children are unauthorized practice of law in this district; that finding alone supports a motion to strike claims brought on behalf of the minors regardless of any AI defects.

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Sanctions cases

From the blog

Sources

Primary sources

Unverified claims:
  • The Sevilla case is not in the Charlotin tracker as of May 2026; verification of the AI-related footnote relied on the CourtListener docket entry text for Doc. 163 rather than a separately retrieved order PDF. The 'hallmarks of motions created using artificial intelligence or found on the internet' phrasing is the verbatim footnote per the docket extraction.
  • The order is procedurally complex: the December 31, 2025 omnibus order denies roughly 80+ motions without prejudice, including motions for TROs, sanctions, recusal, and appointment of counsel. The AI-citation observation appears as a footnote tied to the shotgun-pleading discussion, not as a separately styled Rule 11 warning.
  • The plaintiffs purported to represent their minor children pro se; the court ordered that minors cannot be listed as plaintiffs unless represented by counsel. The pro se status applies to the parent-plaintiffs only; any child-plaintiff claims required separate representation.