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HomeCasesMcCarthy v. U.S. Drug Enforcement Administration
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Corpus matter record

McCarthy v. U.S. Drug Enforcement Administration

3rd Cir. CA · Mar 27, 2026

/ federalEditorial impact: highfake citationsmisrepresented authoritybar referraladministrativeProfessional
Direct answer

What happened in this matter?

The Third Circuit sanctioned attorney Daniel A. Pallen for filing briefs containing AI-hallucinated and inaccurate case law. The court issued a formal reprimand and mandated that the disciplinary action be reported to other courts and the National Disciplinary Data Bank, citing the attorney's failure to verify citations despite having notice of potential errors.

Why the court cared
The Court reasoned that the attorney violated Pa. R.P.C. 1.1 (competence) and Circuit Disciplinary Rule 2.1(d) by failing to perform a reasonably diligent inquiry into the accuracy of cited authorities. The Court emphasized that the attorney's conduct was particularly egregious because he continued to rely on the unverified citations even after the Government identified the errors and he suspected AI involvement.
Why it matters now
Third Circuit now notifies the National Disciplinary Data Bank on AI fabrications — one reprimand follows you circuit-wide.

Why this matter is tracked

Attorney Daniel A. Pallen submitted an Opening Brief to the Third Circuit containing eight summaries of DEA adjudications, seven of which were inaccurate and one of which was entirely fabricated. The attorney relied on AI-generated research provided by a non-attorney without verifying the existence or accuracy of the citations. Despite being alerted to these errors by the Government, the attorney failed to verify the citations and subsequently filed a Reply Brief characterizing the errors as immaterial. The Court found that the attorney violated Pa. R.P.C. 1.1 and Circuit Disciplinary Rule 2.1(d). The Court imposed a formal reprimand and ordered notification of the disciplinary action to other courts and the National Disciplinary Data Bank.

Operational lesson

Third Circuit now notifies the National Disciplinary Data Bank on AI fabrications — one reprimand follows you circuit-wide.

Record details

Court3rd Cir. CA
Jurisdictionfederal
Circuit3rd Circuit
DateMar 27, 2026
UN
AI toolUnidentified
Party typeLawyer
OutcomeThe attorney received a formal reprimand, and the Court ordered that the disciplinary action be reported to other courts and the National Disciplinary Data Bank.
Known amountNot recorded
Professional sanctionFormal reprimand and notification to other courts and the National Disciplinary Data Bank.
Attribution boundary

What the record establishes about AI use

admitted

The court refers to the tool as AI-generated without naming a specific platform.

Procedural posture

The matter arose from an underlying appeal (No. 24-2704) where the Court ordered the attorney to show cause regarding the submission of fabricated authorities. Following a hearing on August 11, 2025, the Court issued a formal opinion imposing sanctions.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

2 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | One cited DEA adjudication in the Opening Brief was entirely fabricated (did not exist); discovered when the Court ordered copies of the cited authorities.
  2. Misrepresented: Case Law | Seven DEA-adjudication summaries were riddled with factual and legal inaccuracies and misrepresented the adjudications (e.g., portrayed lesser sanctions than actually imposed); the summaries were AI-generated and not verified by counsel.

Questions this record answers

What happened in McCarthy v. U.S. Drug Enforcement Administration?
The Third Circuit sanctioned attorney Daniel A. Pallen for filing briefs containing AI-hallucinated and inaccurate case law. The court issued a formal reprimand and mandated that the disciplinary action be reported to other courts and the National Disciplinary Data Bank, citing the attorney's failure to verify citations despite having notice of potential errors.
Why does McCarthy v. U.S. Drug Enforcement Administration matter for legal AI risk?
Third Circuit now notifies the National Disciplinary Data Bank on AI fabrications — one reprimand follows you circuit-wide.
What does the public record establish about McCarthy v. U.S. Drug Enforcement Administration?
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 McCarthy v. U.S. Drug Enforcement Administration 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.

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