Anthony C. Hill v. Workday, Inc. (2)
N.D. California · Apr 28, 2026
- Jurisdiction
- federal
- Court
- N.D. California
- Record ID
- anthony-c-hill-v-workday-inc-2-2026-04-28
- Observed outcome
- The court admonished Attorney Lenden Webb, imposed a $1,001 personal fine, ordered four hours of live CLE, and required the circulation of sanctioning orders and CLE materials to firm staff.
- Known monetary consequence
- $1,001
Why this matter warrants attention
The court sanctioned Attorney Lenden Webb for filing a brief containing a fabricated citation and misrepresented authority, which was partially attributed to the use of the CoCounsel AI tool. The court ordered an admonishment, a $1,001 personal fine, four hours of live CLE, and mandatory circulation of the sanctioning orders and CLE materials within the attorney's firm.
The court reasoned that the attorney of record has a non-delegable duty to verify the accuracy of all citations in filings, regardless of the research source. The court found that the attorney's failure to supervise junior staff and his reliance on AI tools without adequate verification undermined the judicial process and the rule of law. The court determined that sanctions were necessary to deter future misconduct and to reinforce the professional obligations of managing attorneys.
This case underscores that managing attorneys are personally responsible for verifying AI-generated research. It establishes that even a single instance of a fabricated citation warrants sanctions, and that firm-wide remedial measures, such as mandatory CLE and internal circulation of orders, are standard responses to supervision failures.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Employment
- Trial
- Monetary
- Warning
- AI attribution
- Admitted
- Recorded tool
- CoCounsel
- Known monetary consequence
- $1,001
- Procedural posture
- Order following an Order to Show Cause regarding professional conduct and supervision failures.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The attorney used Westlaw's CoCounsel AI tool.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to CoCounsel output as to any other research input.