Dillon v. Myles Stephenson, et al.
W.D. Oklahoma · Mar 11, 2026
What happened in this matter?
The court issued a formal admonishment to plaintiffs' counsel after discovering three incorrect legal citations in their briefing. The court noted that while generative AI is not inherently prohibited, counsel's failure to verify the existence and accuracy of cited authorities violated the duty of reasonable inquiry under Fed. R. Civ. P. 11(b)(2).
- Why the court cared
- The court reasoned that the inclusion of non-existent cases and misattributed reporter citations indicated a failure to perform the reasonable inquiry required by Fed. R. Civ. P. 11(b)(2). The court cited the Tenth Circuit's guidance that while AI use is not inherently problematic, careless use wastes judicial resources and damages the credibility of the legal system.
- Why it matters now
- Reporter citations must be pulled and confirmed — even one mismatched cite earns a public admonishment on the record.
Why this matter is tracked
In a civil rights action, the court identified three incorrect legal citations in the plaintiffs' response brief regarding the Oklahoma Governmental Tort Claims Act. Although plaintiffs' counsel denied using generative AI, the court noted that the nature of the errors—including citations to non-existent cases and misattributed propositions—suggested reliance on generative AI tools. The court emphasized that counsel's duty of reasonable inquiry under Fed. R. Civ. P. 11(b)(2) requires verifying the accuracy of all legal authorities. Consequently, the court issued a formal admonishment to plaintiffs' counsel, warning that future submissions containing similar errors or the impermissible use of generative AI would result in the imposition of sanctions.
Reporter citations must be pulled and confirmed — even one mismatched cite earns a public admonishment on the record.
Record details
What the record establishes about AI use
The court identified the errors as potentially resulting from a generative-AI program.
Order on Motion to Dismiss
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.
- Misrepresented: Case Law | Court found reporter citation incorrect; a case with the same name exists but the cited reporter and proposition are incorrect/misrepresented.
- Fabricated: Case Law | Court found citation does not exist and is unrelated to the GTCA.
- Fabricated: Case Law | Court found citation does not exist and is unrelated to the GTCA.
Questions this record answers
- What happened in Dillon v. Myles Stephenson, et al.?
- The court issued a formal admonishment to plaintiffs' counsel after discovering three incorrect legal citations in their briefing. The court noted that while generative AI is not inherently prohibited, counsel's failure to verify the existence and accuracy of cited authorities violated the duty of reasonable inquiry under Fed. R. Civ. P. 11(b)(2).
- Why does Dillon v. Myles Stephenson, et al. matter for legal AI risk?
- Reporter citations must be pulled and confirmed — even one mismatched cite earns a public admonishment on the record.
- What does the public record establish about Dillon v. Myles Stephenson, et al.?
- 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 Dillon v. Myles Stephenson, et al. 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.