Blake Lewis v. Entergy Mississippi, LLC
S.D. Mississippi · Sep 3, 2025
What happened in this matter?
The court issued an order to show cause requiring counsel to explain the submission of fabricated and misrepresented case law in a court filing. The court explicitly raised concerns that the errors resulted from the use of generative AI, which is known to produce hallucinated citations, and ordered counsel to justify why sanctions should not be imposed.
- Why the court cared
- The Court reasoned that the submission of non-existent or misrepresented authorities violates Federal Rule of Civil Procedure 11(b), Mississippi Rule of Professional Conduct 3.3, and Local Rule 83.1(c)(1), necessitating a show-cause hearing to determine if sanctions are appropriate.
- Why it matters now
- Ban non-firm-approved consumer AI services in writing; unauthorized tool use is the fastest path to a show-cause order.
Why this matter is tracked
In Blake Lewis v. Entergy Mississippi, LLC, the U.S. District Court for the Southern District of Mississippi issued a sua sponte order to show cause regarding counsel's use of fabricated legal authorities. The Court identified multiple citations in the plaintiff's opposition brief that could not be located or were fundamentally misrepresented, including cases that did not exist or held the opposite of the proposition cited. The Court expressed concern that these filings violated Federal Rule of Civil Procedure 11(b), Mississippi Rule of Professional Conduct 3.3, and Local Rule 83.1(c)(1), specifically noting the potential use of generative AI. Counsel was ordered to provide a sworn declaration explaining the discrepancies and justifying why sanctions should not be imposed.
Ban non-firm-approved consumer AI services in writing; unauthorized tool use is the fastest path to a show-cause order.
Record details
What the record establishes about AI use
The court noted the potential use of generative AI but did not identify a specific tool.
Order to show cause issued by the Magistrate Judge on September 3, 2025, following the filing of an opposition brief containing problematic citations.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Counsel cited Matherne v. Cytec Corp., 78 F. App'x 977, 978 (5th Cir. 2003) as reversing a stay; the Court could not locate that opinion and research returned an unrelated Fifth Circuit decision (United States v. Strain).
- Fabricated: Case Law | Counsel cited Von Drake v. Nat'l Sec. Agency, 156 F.3d 181, 1998 WL 546172, at *2 (5th Cir. 1998) for the proposition that an appellate court reversed a stay; the Court's searches did not locate such an opinion.
- Misrepresented: Case Law | Counsel cited Fujita v. United States, 416 F. App'x 400, 402 (5th Cir. 2011) as affirming denial of a stay; the Court found the Fujita opinion actually affirmed the district court's grant of a stay and stated the stay was proper.
Questions this record answers
- What happened in Blake Lewis v. Entergy Mississippi, LLC?
- The court issued an order to show cause requiring counsel to explain the submission of fabricated and misrepresented case law in a court filing. The court explicitly raised concerns that the errors resulted from the use of generative AI, which is known to produce hallucinated citations, and ordered counsel to justify why sanctions should not be imposed.
- Why does Blake Lewis v. Entergy Mississippi, LLC matter for legal AI risk?
- Ban non-firm-approved consumer AI services in writing; unauthorized tool use is the fastest path to a show-cause order.
- What does the public record establish about Blake Lewis v. Entergy Mississippi, LLC?
- 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.
- Which source supports this Blake Lewis v. Entergy Mississippi, LLC summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.