Dillon v. Myles Stephenson, et al.
W.D. Oklahoma · Mar 11, 2026
- Jurisdiction
- federal
- Court
- W.D. Oklahoma
- Record ID
- dillon-v-myles-stephenson-et-al-2026-03-11
- Observed outcome
- The court granted the defendant's motion to dismiss and issued a formal admonishment to plaintiffs' counsel regarding the inclusion of incorrect legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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).
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.
Reporter citations must be pulled and confirmed — even one mismatched cite earns a public admonishment on the record.
Failure modes and consequences
- Hallucinated_case_law
- Misrepresented_authority
- Fake Citations
- Misrepresented Authority
- Civil Rights
- Trial
- AI attribution
- Implied
- Recorded tool
- generative-AI program
- Known monetary consequence
- Not recorded
- Procedural posture
- Order on Motion to Dismiss
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 errors as potentially resulting from a generative-AI program.
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, including cross-referencing reporter volumes and page numbers against official databases.
- Maintain a documented audit trail of the research process for every filing to demonstrate compliance with the duty of reasonable inquiry.
- Establish firm-wide policies requiring independent human review of any research output generated by AI tools before inclusion in court submissions.