Mid Cent. Operating Eng'rs Health v. Hoosiervac
S.D. Indiana · May 28, 2025
- Jurisdiction
- federal
- Court
- S.D. Indiana
- Record ID
- mid-cent-operating-engrs-health-v-hoosiervac-2025-05-28
- Observed outcome
- The court adopted the recommendation in part, ordering counsel to pay a $6,000 monetary sanction to the Clerk of the Court.
- Known monetary consequence
- $6,000
Why this matter warrants attention
The court imposed a $6,000 monetary sanction on counsel for violating Rule 11 by submitting three briefs containing non-existent, AI-generated case citations. The court determined this amount was sufficient to deter future misconduct, considering the attorney's admitted failure to verify citations and the collateral professional consequences already experienced.
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.
Failure modes and consequences
- Fabricated Case Law
- Lack Of Citation Verification
- Fake Citations
- Other
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified generative AI tools
- Known monetary consequence
- $6,000
- Procedural posture
- Order on Report and Recommendation regarding Rule 11 sanctions.
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
Counsel admitted using generative AI tools.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Read the linked source and subsequent docket history before relying on this record for legal work.