In a July 14th decision, a federal judge in New Jersey ordered pro se litigant Richard Zelma to explain why his brief in a TCPA case contained numerous quotes that did not exist in the actual court decisions he cited. Zelma v. Wonder Group, Inc, No. 25cv3232, Lexis 135885, (U.S. Dist. N.J July 14, 2025). Judge Evelyn Padin noted: “[t]here are several quotations, citations, and cases in Plaintiff’s opposition to Defendant’s Motion to Dismiss that, after an extensive review, the Court cannot find. In some instances, Plaintiff quotes language in cases, but the Court cannot find those quotations.”
She then ordered him to produce copies of the decisions he cited and whether he used generative AI to create his briefs. The Defendant had moved for sanctions against Zelma. Even though sanctions are rarely awarded against pro se litigants, blatant fraud on the Court may be one of those rare times.
Zelma has been a repeat TCPA litigator for decades. The Federal court database shows at least 20 filed cases in New Jersey alone since 2008. In this case, if he cannot show good reason for the errors, could damage that business if his allegations can no longer be considered truthful in this or in other cases.