Kaufman v. Upton
D. Massachusetts · Jan 21, 2026
- Jurisdiction
- federal
- Court
- D. Massachusetts
- Record ID
- kaufman-v-upton-2026-01-21
- Observed outcome
- Referral of attorney Roger A. Peace to the Massachusetts Board of Bar Overseers for potential disciplinary action.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court referred attorney Roger A. Peace to the Massachusetts Board of Bar Overseers for potential discipline after he submitted filings containing fabricated, likely AI-generated citations. The court determined that the attorney's failure to provide a transparent explanation for the errors, instead blaming a clerical mistake, warranted referral for potential violations of the duty of candor.
Fabricated: Case Law | Court found plaintiff's filings contained AI-generated citations to nonexistent authority; counsel attributed them to a version-control/clerical error and did not explain AI use; court treated them as false authority warranting referral.
If citations are challenged, disclose AI use immediately; blaming 'clerical error' escalates a fine into a bar referral.
Failure modes and consequences
- Hallucinated_citations
- Lack_of_candor_in_response
- Fake Citations
- Bar Referral
- Other
- Trial
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order referring counsel to the Board of Bar Overseers following a show-cause proceeding regarding the submission of false authority.
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 refers to 'AI-generated citations' without naming a specific tool.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Escalate and correct a suspect filing promptly, with a documented response.
- Follow any applicable disclosure and attribution requirements for AI-assisted work.