Peters v. Banner Health, 4:24-cv-00772

Plaintiff (pro se) filed consolidated objections to five discovery/motion-related orders; objections were filed Aug. 4, 2025 and docketed at ECF 255.
The Magistrate Judge struck the objections for failure to comply with Fed. R. Civ. P. 11, General Order 2025-04 (use of generative AI), and the Court’s April 26 and May 9 orders.
Plaintiff relied on two Fifth Circuit authorities (Squyres and Geiserman) in support of her position that the court erred in finding good cause for deadline extensions; the quoted parentheticals she attributed to those opinions do not appear in those cases.
The court found this misattribution part of a broader pattern: prior warnings had been issued about using AI-generated content and about citing nonexistent or mischaracterized authority; Plaintiff had submitted AI Compliance Statements in other filings but did not attach one to the consolidated objections.
The Magistrate Judge emphasized that pro se status does not excuse Rule 11 obligations, concluded the filings wasted judicial resources, struck the objections, and warned that continued misrepresentation could lead to monetary sanctions or a recommendation of dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Compliance with Rule 11 and General Order on AI	Objections were proper and supported by controlling precedent (cited Squyres, Geiserman)	Objections failed Rule 11 and violated General Order 2025-04 and prior court orders	Objections struck for noncompliance with Rule 11, General Order 2025-04, and court orders
Accuracy of cited authority	Quoted language from Squyres and Geiserman supports Plaintiff’s position	Plaintiff misquoted/misattributed language; cited parentheticals do not appear in those opinions	Court found citations inaccurate and misleading; this supported striking the objections
Use of generative AI in filings	Plaintiff submitted AI-use compliance in other filings and asserted review/approval	Plaintiff failed to attach AI compliance statement to the consolidated objections and did not verify citations	Court noted failure to attach compliance statement and reiterated requirement to verify AI-generated content
Sanctions for continued misrepresentations	Plaintiff implicitly contended no sanction warranted	Court warned Rule 11 applies to pro se litigants; misrepresentation may waste resources	Court warned of possible monetary sanctions and recommendation of dismissal if misrepresentations continue

Squyres v. Heico Cos., LLC, 782 F.3d 224 (5th Cir. 2015) (discusses standards for scheduling-order modifications and good-cause inquiries)
Geiserman v. MacDonald, 893 F.2d 787 (5th Cir. 1990) (addresses strict enforcement of scheduling orders and need for diligence)
Park v. Kim, 91 F.4th 610 (2d Cir. 2024) (criticizes reliance on misleading or fabricated authority and describes such conduct as an abuse of the adversary system)