Two days before Christmas, a district court in Nebraska cautioned a pro se litigant about using generative AI in his legal memoranda.
In the motion to reconsider, Leber raises the same arguments the Court rejected in his motion for partial final judgment. In “support” of his arguments, Leber repeatedly cites to a case which appears to be a hallucination of artificial intelligence, despite Leber’s certification that he has “reviewed and verified the accuracy of all content, citations, and legal authority referenced” in his filing (Filing No. 68-1).[1] The Court had previously warned Leber about this in its previous order. And Leber’s pro se status does not excuse him from “comply[ing] with court rules and directives.” See Soliman v. Johanns, 412 F.3d 920, 922 (8th Cir. 2005). Leber is again instructed to verify the accuracy of all content, citations, and legal authority in his filings. See Fed. R. Civ. P. 11(b); NECivR 7.1(d)(5) (providing that “[a]ny brief not in compliance with this subsection may be stricken”— without further notice—”in the sole discretion of the court” and that a “material misrepresentation in the certificate of compliance” may also result in “sanctions against the person signing the document”).
The court denied the motion to reconsider. The citation is Leber v. Bryan Medical Center, D. Nebraska 2025, 8:25 cv 401.