Jackie L. Miller v. Regions Bank
N.D. Alabama · May 21, 2026
- Jurisdiction
- federal
- Court
- N.D. Alabama
- Record ID
- jackie-l-miller-v-regions-bank-2026-05-21
- Observed outcome
- The attorney was disqualified from the case and the court for six months and referred to the state bar for disciplinary action.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court sanctioned the attorney for submitting fabricated legal quotations and destroying evidence (his ChatGPT history) after being ordered to produce it. The court imposed a six-month disqualification from the case and the court, and referred the attorney to the state bar for disciplinary proceedings.
The court found the attorney violated Rule 11 by presenting legal contentions not warranted by existing law. It drew an adverse inference of AI usage because the attorney acted in bad faith by deleting his ChatGPT account after being ordered to produce it, thereby destroying evidence crucial to the sanctions inquiry.
This case illustrates the severe consequences of combining AI-generated hallucinations with subsequent spoliation of evidence. It highlights that courts may draw adverse inferences regarding AI usage when an attorney destroys digital evidence during a sanctions inquiry.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Bar Referral
- Employment
- Trial
- Professional
- AI attribution
- Implied
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- Procedural posture
- Sua sponte sanctions proceeding under Federal Rule of Civil Procedure 11 following the submission of a response brief containing fabricated legal authorities.
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 admitted to using ChatGPT for general search.
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.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to ChatGPT output as to any other research input.