An incarcerated murder-for-hire convict in a federal lawsuit over whether an animal sanctuary can neuter a white Bengal tiger named Elvis that the plaintiff used to own is already hallucinatory enough without the case citations being fake.
Joseph Maldonado — better known to everyone who Netflix-ed their way through the pandemic as Joe Exotic — is currently housed at FMC Fort Worth, where he pesters Donald Trump for a pardon and an administration position at Fish and Wildlife. But he’s also suing Black Pine Animal Sanctuary in the Northern District of Indiana over the fate of four tigers seized from Maldonado’s former associates Jeff and Lauren Lowe back in 2022. The sanctuary announced plans to neuter Elvis, one of the white Bengals, prompting Maldonado, through counsel Roger Roots, to file a federal suit under the Endangered Species Act.
Fast forward to Chief Judge Holly Brady’s February 27 show cause order. Judge Brady ran her own research on Maldonado’s work in the case and discovered a plethora of made up cases. The complaint anticipates the standing challenge (which the court had flagged in a prior iteration of this same case) by citing a case that… doesn’t exist.
The Court searched for that case with that citation, but the case number leads to an unrelated debt case and the Westlaw identifier returns no result at all. And while a case with that name exists with a different case number, there is no order for that date and no order that makes any reference to standing beyond the fact that the defendants never challenged or even brought up the Plaintiff’s standing.
Twice more, Judge Brady notes, counsel cited cases that “technically exist but cannot be found at his provided citation, have no order on his cited date, and apparently do not support what he represents to the Court.” The footnote catalogues two such entries. A PETA v. Wildlife in Need cite that resolves to a Western District of Virginia criminal matter, and a PETA v. Tri-State Zoological Park cite that resolves to an SDNY employment case.
The opposition brief is, in Brady’s words, “an extensive affair which at times reads more like a legal treatise on the ESA as opposed to a legal brief.” Which is judicial speak for “I ain’t reading all that — I’m happy for u tho. Or sorry that happened.” The brief lists various “ESA injuries” with supporting caselaw, and the caselaw — the caselaw that actually exists — doesn’t support the propositions.
For instance, he cites In Defense of Animals v. National Institutes of Health, 543 F. Supp. 70 (D.D.C. 2008), for his assertion that “Loss of scientific data, interruption of research, or inability to continue long-term animal studies constitutes injury-in-fact” and that “[c]ourts emphasize that scientific frustration is a valid injury even without direct physical access.” (ECF No. 17 at 15). But not only is In Defense of Animals a Freedom of Information Act case with no reference or connection to the ESA, the opinion does not mention standing, scientific injuries, or anything that would support Maldonado’s proposition.
And it keeps going like that. One case described as “Conservation and scientific professionals have standing when mistreatment of animals disrupts their work,” actually concluded that a circus elephant handler didn’t have an injury-in-fact just because he wanted to work with the elephants again. As Judge Brady wrote, “while other ESA cases might support his contention about standing for emotional injuries, the case he chose was explicitly not among them.”
This raises the obvious 2026 question: did counsel use generative AI to produce this filing?
While these cases and citations were not fully fabricated, as is often the story, the inaccuracies and misrepresentations nevertheless bear much resemblance to other instances in which pro se litigants or attorneys have relied on generative AI to produce their filings, in part or in full. See, e.g., Jones v. Kankakee Cnty. Sherriff’s Dep’t, 164 F.4th 967, 969 (7th Cir. 2026) (“To our eye, the error has all the hallmarks of a so-called AI “hallucination,” a circumstance where an AI large language model generates an output that is fictional, inaccurate, or nonsensical.”). Although these aren’t quite the typical hallmarks of AI hallucination, the legal misrepresentations, nonexistent citations, and length policy sections altogether are too fishy for the Court to believe. There is something rotten in the Northern District of Indiana, and it’s not the fish being fed to Maldonado’s former tigers.
As we noted recently, humans are fully capable of producing this kind of slop without Claude or ChatGPT’s help. As Brady explains, “But even if Maldonado’s counsel did not use AI for his filings, the Court is deeply concerned by these blatant misrepresentations of law.”
We are now past 1,000 documented AI hallucination cases globally. Sullivan & Cromwell — the firm that represents OpenAI — just had to file an emergency letter explaining why its Prince Global Holdings brief was riddled with hallucinated citations. Gordon Rees is now a serial offender. Butler Snow got three lawyers kicked off a case. Courts are losing patience.
The lawyer responded, pinning responsibility on a paralegal filing a non-final draft. “Although he does not directly address the use of AI for the filings, that use can be read between the lines,” wrote Judge Brady in her opinion. Ultimately, the attorney received a $1,500 fine and a bar referral.
Elvis… not as lucky.
(Order to Show Cause on next page…)
Joe Patrice is a senior editor at Above the Law and co-host of Thinking Like A Lawyer. Feel free to email any tips, questions, or comments. Follow him on Twitter or Bluesky if you’re interested in law, politics, and a healthy dose of college sports news. Joe also serves as a Managing Director at RPN Executive Search.
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