Bailey v. Sedgwick Claims Management Services, Inc.
W.D. Tennessee · Jun 8, 2026
- Jurisdiction
- federal
- Court
- W.D. Tennessee
- Record ID
- bailey-v-sedgwick-claims-management-services-inc-2026-06-08
- Observed outcome
- The Court ordered the submission of a corrected motion to replace the filing containing AI-hallucinated citations and false quotes.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court ordered Plaintiff's counsel to correct a motion containing AI-hallucinated citations and false quotes. While the Court acknowledged the conduct was sanctionable under Sixth Circuit precedent, it declined to impose formal sanctions, opting instead to issue a warning and require the submission of a corrected filing.
The Court reasoned that while citing fake cases is sanctionable, it exercised discretion to withhold sanctions, noting the hope that counsel had received the message regarding their duty of competence and the necessity of verifying all authorities.
This case illustrates judicial oversight of AI-assisted drafting, highlighting that courts may prioritize correction over formal sanctions when counsel acknowledges errors and remedies them, while still reinforcing the non-delegable duty of verification.
Failure modes and consequences
- Hallucinated_citations
- Fabricated_quotes
- Fake Citations
- Fabricated Quotes
- Contract
- Trial
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Order granting corrected motion for preliminary approval of settlement following a status conference regarding AI-generated errors in a prior filing.
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 Court identified the use of an AI tool to draft the motion.
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
- Implement mandatory verification protocols for all case law citations and quotations generated by AI tools.
- Conduct independent review of all AI-drafted filings to ensure accuracy and compliance with ethical obligations.
- Maintain internal records of AI tool usage to facilitate transparency if questioned by the court.