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Tiger King Attorney Sanctioned for Filing Complaint with AI Hallucinations

Another example of the risks of relying upon AI tools to assist in legal research.

Jonathan H. Adler | 4.12.2026 10:04 AM

Joseph Maldonado, aka Joe Exotic, may be in prison (for charges of animal abuse and attempted murder), but he continues to make legal news.

In 2025, the former reality-TV star sued the Black Pine Animal Sanctuary alleging it mistreated four of the Tiger King's former tigers in violation of the Endangered Species Act (ESA). On April 1, a district court in Indiana dismissed Maldonado's suit for lack of Article III standing. It also sanctioned Maldonado's attorney (Roger Roots) for filing a complaint and other documents containing imaginary citations and misrepresentations of authorities, likely as a consequence of using AI. While the sanctions were not large ($1,500), the court also referred Roots to the Rhode Island disciplinary authorities.

The court's opinion in Maldonado v. Professional Animal Retirement Center begins:

"Are the animals happy? Who the hell knows?" Certainly not Plaintiff Joseph Maldonado, who uttered those words in a 2020 Netflix documentary1 and who is now suing the wildlife park housing some of his former tigers under the citizen suit provision of the Endangered Species Act, 16 U.S.C. § 1540(g) ("ESA"). But Maldonado has no connection to these big cats beyond his personal history with them, nor........

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