Justin Spiehs v. Erik Smith
D. Kansas · Apr 29, 2026
- Jurisdiction
- federal
- Court
- D. Kansas
- Record ID
- justin-spiehs-v-erik-smith-2026-04-29
- Observed outcome
- The court issued a warning to counsel regarding the use of fabricated quotations and potential future sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to the plaintiff's counsel after discovering fabricated case law quotations in a brief, which the court suspected were generated by artificial intelligence. The court explicitly warned that future instances of incorrect quotations could lead to sanctions under Fed. R. Civ. P. 11 and local standing orders.
The court determined the quotes were fabricated after confirming they did not appear in the cited opinions and noting that a Westlaw search for the specific text returned no results.
This case illustrates judicial scrutiny of AI-assisted legal research. It highlights the risk of fabricated case law and the court's willingness to issue formal warnings to counsel to ensure compliance with verification standards.
Failure modes and consequences
- Fabricated Quotes
- Civil Rights
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum and Order on Defendants' motions to dismiss, Plaintiff's motion for preliminary injunction, and Plaintiff's motion to amend complaint.
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 suspected the use of artificial intelligence.
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
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.