M.T. Real Estate Investment Inc. v. Servis One, Inc., et al.
D. Nevada · Dec 30, 2025
- Jurisdiction
- federal
- Court
- D. Nevada
- Record ID
- mt-real-estate-investment-inc-v-servis-one-inc-et-al-2025-12-30
- Observed outcome
- The court struck the offending filings, ordered the attorney to pay the defendants' reasonable attorney's fees and costs, and referred the attorney to the Nevada State Bar Association.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court sanctioned attorney Bryce Finley for violating FRCP 11(b)(2) by submitting five fabricated legal authorities generated by AI. The court struck the offending filings, ordered the payment of the defendants' reasonable attorney's fees and costs incurred in addressing the hallucinations, and referred the attorney to the Nevada State Bar Association.
Fabricated: Case Law | Court could not locate the district court opinion cited; counsel admitted the citation was not real and produced by AI. || Fabricated: Case Law | Court could not locate the Nevada decision cited; counsel admitted the cited state-court opinion was not real and was AI-generated. || Fabricated: Doctrinal Work | Court could not locate the practice guide/treatise cited; counsel admitted the reference was not real and generated by AI. || Fabricated: Case Law | Court could not locate the opinion cited; counsel later admitted the cited decision was not real and was AI-generated. || Fabricated: Case Law | Court could not locate the Ninth Circuit opinion cited; counsel admitted the citation was not real and produced by AI.
Bar referral follows multiple fabricated cites in one brief; require Westlaw/Lexis pinpoint verification log for every AI-assisted filing.
Failure modes and consequences
- Fake Citations
- Bar Referral
- Contract
- Trial
- Monetary
- Struck Filing
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued an order imposing sanctions following a show-cause proceeding regarding the submission of non-existent legal authorities in response to motions to dismiss and strike.
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 attorney admitted the citations were the product of artificial intelligence.
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.
- Do not treat a paid legal-research product as a substitute for source verification.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.