Shaporov v. PIPPD P.O. Matthew Levine
U.S. District Court, District of New Jersey · D.N.J. · New Jersey bar guidance
Verified April 26, 2026
- Citation
- Shaporov v. PIPPD P.O. Matthew Levine, No. 2:22-cv-01150 (D.N.J. Sept. 25, 2025)
- Decided
- September 25, 2025
Summary
Pro se plaintiff Alexander Shaporov filed a brief opposing summary judgment in a Section 1983 action arising from a 2020 traffic stop on the Palisades Interstate Parkway. The brief attributed a verbatim quotation to Camiolo, a precedential Third Circuit decision, but the language did not appear in Camiolo. The quoted passage instead appeared in Frohner v. City of Wildwood, a non-binding D.N.J. opinion that Shaporov cited elsewhere in the same brief. The court flagged the misattribution as bearing the hallmarks of generative-AI-fabricated authority and entered an order to show cause.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause issued directing Shaporov to explain why the misattributed quotation should not result in sanctions. No monetary penalty imposed at the show-cause stage; further proceedings to follow on the response.
Why does Shaporov v. PIPPD P.O. Matthew Levine matter for law firms using AI?
Shaporov is a pro se hallucination matter, not an attorney-discipline case, but it illustrates a pattern firms should expect to see from adverse pro se litigants: a real reporter citation paired with a quotation lifted from a different, correctly-cited case in the same brief. For defense counsel, the takeaway is procedural. Verifying that quoted language actually appears in the cited authority is now a routine part of opposing-brief review, not an exotic check reserved for suspicious filings.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- The order does not expressly name the AI tool used; the AI attribution is inferred from the misquotation pattern.