McCormick v. Texakoma Financial
E.D. Texas · Jun 11, 2026
What happened in this matter?
The court sanctioned attorney Amy L.B. Ginsburg for filing a brief containing fictitious case law and fabricated quotes, likely generated by AI. Sanctions included a public reprimand, a $5,000 penalty, mandatory CLE, a comprehensive firmwide citation audit, and a one-year requirement to certify the verification of all future citations in the district.
- Why the court cared
- The court found that Ginsburg failed to perform a reasonable inquiry into the veracity of citations and quotes, violating Rule 11(b). The court rejected her 'wrong version' and 'clerk error' explanations as not credible, noting that even a cursory review would have revealed the fictitious nature of the authorities. The court determined that financial sanctions alone were insufficient to deter future misconduct, necessitating a public reprimand and mandatory remedial measures to safeguard the integrity of the judicial process.
- Why it matters now
- This case illustrates the high threshold for judicial credibility when counsel blames AI-generated hallucinations on staff. It establishes a rigorous remedial framework for attorneys who fail to verify AI-assisted filings, emphasizing that public reprimands and mandatory audits are increasingly viewed as necessary deterrents.
Why this matter is tracked
In a TCPA action, Plaintiff's counsel, Amy L.B. Ginsburg, submitted a summary judgment response containing a fictitious case, fabricated quotations, and multiple unsupported legal propositions. The court issued an order to show cause after defense counsel identified these errors. Ginsburg attributed the errors to a law clerk's use of AI and a paralegal's filing of an incorrect draft, but the court found her explanation lacked credibility. The court imposed a public reprimand, a $5,000 penalty, mandatory CLE on AI ethics and candor, a firmwide citation review of all filings since January 2026, and a requirement for a signed certification of verification for all future filings in the district for one year.
This case illustrates the high threshold for judicial credibility when counsel blames AI-generated hallucinations on staff. It establishes a rigorous remedial framework for attorneys who fail to verify AI-assisted filings, emphasizing that public reprimands and mandatory audits are increasingly viewed as necessary deterrents.
Record details
What the record establishes about AI use
Counsel admitted law clerk used AI to assist in drafting.
Order to show cause issued May 15, 2026; hearing held May 28, 2026; sanctions order issued June 11, 2026.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | A cited case, 'Noviello v. Bayview Asset Management, LLC, No. 3:18-cv-02057, 2019 WL 13175252, at *4 (N.D. Tex. Sept. 30, 2019)', was fictitious and does not exist as presented.
- False Quotes: Case Law | Two quoted passages attributed to Texas v. American Blastfax, Inc. (164 F. Supp. 2d 892 (W.D. Tex. 2001)) do not appear in that opinion and were fabricated.
- Misrepresented: Case Law | Citation to Gene & Gene LLC v. BioPay LLC, 541 F.3d 318 (5th Cir. 2008) was used to support a proposition about the §227(c)(5) safe-harbor requiring actual compliance, but the cited pages do not support that proposition.
- Misrepresented: Case Law | Citation to Charvat v. GVN Mich., Inc., 561 F.3d 623 (6th Cir. 2009) was used to support a burdens-of-proof proposition that the court found unsupported by the cited material.
- Misrepresented: Case Law | Citation to Shields Ltd. P'ship v. Bradberry, 526 S.W.3d 471 (Tex. 2017) was used to assert a duty-to-speak estoppel principle that the Court found the cited pages do not establish.
Questions this record answers
- What happened in McCormick v. Texakoma Financial?
- The court sanctioned attorney Amy L.B. Ginsburg for filing a brief containing fictitious case law and fabricated quotes, likely generated by AI. Sanctions included a public reprimand, a $5,000 penalty, mandatory CLE, a comprehensive firmwide citation audit, and a one-year requirement to certify the verification of all future citations in the district.
- Why does McCormick v. Texakoma Financial matter for legal AI risk?
- This case illustrates the high threshold for judicial credibility when counsel blames AI-generated hallucinations on staff. It establishes a rigorous remedial framework for attorneys who fail to verify AI-assisted filings, emphasizing that public reprimands and mandatory audits are increasingly viewed as necessary deterrents.
- What does the public record establish about McCormick v. Texakoma Financial?
- 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 McCormick v. Texakoma Financial 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.