Some of the about 80 lawyers and legal organizations Zhong reached out to didn't want to go up against institutions with far more legal resources, and others worried that they might even receive threats if they handled the suits alleging discrimination against Asian American applicants.
So Zhong, who is a software engineering manager at Google, and his son turned to artificial intelligence to draft and file their complaints in early 2025.
"For people like me, who speak English as a second language and have no formal legal training whatsoever, AI is a game changer," Zhong told Law360 Pulse. "With AI, we are now able to draft and file legal briefs, and navigate the legal system."
While Zhong has had some early success in his suits, he and other pro se litigants face what some scholars have presented as a surprising paradox: AI appears to have contributed to a dramatic spike in pro se litigation — with self-represented litigants' share of federal court filings roughly doubling since ChatGPT was first released — but the technology isn't necessarily helping these litigants find success in court.
Some research indicates that the technology has had little effect on case outcomes, while other data suggests that AI-drafted lawsuits are dismissed earlier and more often than lawsuits filed without the aid of large language models.
"More people are walking into court, so it seems like access has gone up," said Joshua Y. Levy, an economics Ph.D. student at the University of Southern California and co-author of a paper about AI's impact on federal court filings.
"Now, how are these cases turning out? It's still very, very, very rare that a pro-se litigant wins their case," Levy said. "So, in a substantive sense, whether people are receiving greater access to justice is sort of unclear."
A Dramatic Increase
AI appears to be the driving force behind a substantial rise in the number of federal court filings from self-represented litigants.
Pro se litigants filed an average of about 23,000 new federal lawsuits each year between 2005 and 2022, the year ChatGPT was first released to the public, according to research from Levy and Massachusetts Institute of Technology Ph.D. student Anand V. Shah. But pro se litigants filed 27,370 suits in 2023, 31,478 in 2024 and 41,490 in 2025, according to Shah and Levy's research.
Levy and Shah found that non-prisoner, self-represented litigants accounted for about 11% of civil federal court filings in the years between 2005 and 2022, but accounted for 14.5% of those filings in 2024 and 16.8% of them in 2025.
"There's undoubtedly an increase in filings. And moreover, it seems like these filings themselves are also heavier. So, there are more motions per each case, maybe the cases themselves have more pages," Shah told Law360 Pulse.
Similarly, pro se litigants accounted for 11.3% of federal civil filings before 2022, according to a June paper by Or Cohen-Sasson, director of the Miami Law & AI Lab at the University of Miami School of Law. By the final quarter of fiscal year 2025, their share of those filings roughly doubled to 22.3%, the paper shows.
It's difficult to pinpoint AI as the specific cause of this increase in filings, but there are several indications that the technology is largely responsible.
For starters, the increase in pro se cases is most obvious in what Shah and Levy refer to as "simple" cases, such as lawsuits involving credit consumer disputes, civil rights violations, foreclosures and employment discrimination, rather than more "complex" cases like patent and product liability suits. Cohen-Sasson also found the biggest increases in pro se-filed litigation in cases involving civil rights, torts, and property and tax disputes.
Secondly, a growing percentage of pro se filings bear the signature of AI-generated text, according to scholars.
Levy and Shah ran a random sample of 1,600 federal civil complaints — 200 from each year between 2019 and 2026 — through the AI-text detection service provided by Pangram Labs. They found that just 0.1% of the filings analyzed were found to contain AI-generated text during the period from 2019 to 2022. That rate increases to 3.5% of filings in 2024, 10.5% in 2025 and 18% in early 2026.
"These results are overwhelmingly only really consistent with a general-purpose technology providing some large technological shift," Shah said. "And they're co-timed with the drop of powerful AI models."
"It has to be something to do with the emergence of AI," echoed Cohen-Sasson.
But Shah and Levy's research doesn't prove a causal link that a pleading wouldn't have been filed but for AI, according to Jason Tashea, director of technology, data and knowledge management at the National Center for State Courts.
"And that's by and large true in all of the analysis that has tried to make similar claims," Tashea said.
The increase in pro se litigation that some scholars point to hasn't just coincided with the rise of AI, but has also come during a time of economic turmoil for much of the country. There have been increases in consumer debt and defaults, which could also drive more pro se litigants into court, according to Tashea.
He points out that federal court filings from pro se litigants also increased during the Great Recession. In fact, filings from self-represented litigants jumped nearly 13% from 2007 to 2013, according to data from the Administrative Office of the U.S. Courts. Those increases clearly weren't driven by AI, which wasn't widely available at the time.
"The thing that the Shah-Levy paper can say is most likely people are using AI more in the drafting of filings. And I mean the answer there is, 'of course,' because everyone's using AI to write everything," Tashea said.
"I think the important question is: Is AI driving litigation that otherwise would not have come to court? And no one has been able to answer that question," he added.
"Not Seeing AI Pay Off"
Just because pro se litigants are increasingly turning to AI to file lawsuits and draft pleadings doesn't mean the tools are helping them win in court, according to scholars. In fact, pro se cases are taking about the same amount of time to resolve, and the distribution of case outcomes — how many cases are dismissed, settled and won or lost at trial — remains largely unchanged, according to Shah and Levy's research.
Judges dismissed approximately 60% of pro se cases before the advent of AI and 63% of pro se cases in the years since AI was widely introduced. Roughly 20% of pro se cases were settled before AI and about 23% are post-AI. Self-represented litigants still win fewer than 1% of cases, just as they did before the AI era, according to Shah and Levy.
AI-drafted filings are actually faring worse by at least some measures, according to Cohen-Sasson.
His research shows that 61.1% of complaints containing a signature of AI-generated text are dismissed, compared to 53.6% of complaints without an AI signature. Suits filed using AI ended before the defendant answered the complaint 47.8% of the time, compared with 39% of complaints that weren't flagged for AI use. And plaintiffs won lawsuits filed using AI at a rate of 6.4%, while they won 8.4% of those cases filed without AI.
At the same time, while an attorney might previously have warned a potential pro se litigant that they had a weak case, AI actually does the opposite, having a tendency to agree with and validate the ideas of those who use it, according to Cohen-Sasson.
Some attorneys pointed to the risks of relying on AI in pro se cases.
"Access to drafting tools is not the same as access to legal judgment," said Jennifer K. McCarty, a Baker Donelson Bearman Caldwell & Berkowitz PC shareholder and co-chair of the firm's labor and employment group. "AI can make a weak or procedurally defective claim look stronger than it is. It can also generate false confidence."
Gallagher Sharp LLP partner James T. Tyminski Jr., who represents Ohio businesses and individuals in matters involving personal injury, wrongful death and property damage, said most pro se litigants would still be better off with a competent attorney than they are with AI.
In one case his firm is handling for a defendant, a pro se plaintiff filed five or six "very lengthy" amended complaints he thinks were drafted with the help of AI, and the court struck the vast majority of those complaints and then threw out her whole case.
"And I think she had a viable enough case that had she had a lawyer to bring it, she would have recovered something," Tyminski said. "We're not seeing AI pay off for them."
In fact, a growing number of judges are expressing frustration with pro se litigants' use of AI when dismissing their suits.
U.S. District Judge Patrick J. Schiltz of the District of Minnesota, for example, offered this rebuke when dismissing one pro se suit: "A litigant cannot dump hundreds of pages of documents on a court and expect the court to sift through."
But Zhong claimed that using AI has worked to his advantage in his racial discrimination suits against the universities. He's used AI to win several procedural victories, including partially defeating a motion to dismiss one of his suits last week.
"It can digest hundreds of pages of legal briefs or precedents, and highlight relevant pieces for our cases in seconds. It can flag legal errors, improper citations, typos, and logical flaws in opposing counsel's filings," Zhong said.
"When opposing counsel tried to bully us with threats of fee shifting, AI instantly called it out and provided pushback that we used with great success," he added.
--Editing by Nicole Bleier and Karin Roberts.
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