Preparing the requested public record.
Preparing the requested public record.
S.D. Indiana · May 28, 2025
Fabricated: Case Law | Brief at docket 39 contained citations to non-existent cases; the magistrate judge could not locate them and Rule 11 violation was admitted. Outcome: Monetary Sanction. (Earlier report and recommendation can be found here.)
Fabricated: Case Law | Brief at docket 39 contained citations to non-existent cases; the magistrate judge could not locate them and Rule 11 violation was admitted. Outcome: Monetary Sanction. (Earlier report and recommendation can be found here.)
Counsel admitted at a show cause hearing that he used generative AI tools to draft multiple briefs and did not verify the citations provided by the AI, mistakenly trusting their apparent credibility without checking.
Three distinct fake cases across filings. Each was cited in a separate brief, with no attempt at Shepardizing or KeyCiting.
The Court recommended a $15,000 sanction ($5,000 per violation), with the matter referred to the Chief Judge for potential additional professional discipline. Counsel was also ordered to notify Hoosiervac LLC’s CEO of the misconduct and file a certification of compliance.Eventually, the court fined Counsel $6,000, stressing that this was sufficient.
The judge stressed that "It is one thing to use AI to assist with initial research, and even nonlegal AI programs may provide a helpful 30,000-foot view. It is an entirely different thing, however, to rely on the output of a generative AI program without verifying the current treatment or validity—or, indeed, the very existence—of the case presented. Confirming a case is good law is a basic, routine matter and something to be expected from a practicing attorney. As noted in the case of an expert witness, an individual's "citation to fake, AI-generated sources . . . shatters his credibility." See Kohls v. Ellison, No. 0:24-cv-03754-LMP-DLM, Doc. 46 at *10 (D. Minn. Jan. 10, 2025)."
Shepardize every AI-surfaced case before filing; repeated unverified briefs stack sanctions across filings.
The current record does not establish a specific AI tool. Do not infer AI use beyond the source.
Monetary Sanction
Correction behavior is not separately verified in the current record.
3 citation, quotation, or authority issues are recorded in the source dataset.
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.