Pauliah v. University of Mississippi Medical Center
S.D. Mississippi · Dec 30, 2025
- Jurisdiction
- federal
- Court
- S.D. Mississippi
- Record ID
- pauliah-v-university-of-mississippi-medical-center-2025-12-30
- Observed outcome
- The court struck the declaration and ordered the plaintiff to pay $1,000 and former counsel to pay $4,000 in sanctions, plus required counsel to complete 3 hours of CLE on AI-generated hallucinations.
- Known monetary consequence
- $5,000
Why this matter warrants attention
The court imposed a $5,000 monetary sanction and a mandatory 3-hour CLE requirement on counsel after finding that a pro se plaintiff and his former attorney submitted a bad-faith declaration containing fabricated deposition quotes and citations generated by AI. The court held both parties responsible for failing to verify the accuracy of the filing against the actual record.
False Quotes: Exhibits & Submissions | Fabricated quotation presented as from Dr. Howard's deposition—"He did not receive adequate departmental support... I loaned my laptop so he could complete the report."—attributed to 'Howard Dep. 33:5-34:3'; court found the quote absent from the transcript and fabricated. || Fabricated: Exhibits & Submissions | Multiple manufactured citations to deposition transcripts accompanying fabricated quotations throughout the sworn declaration; court characterized these as deliberate fabrications undermining the record and struck the entire declaration. || Fabricated: Exhibits & Submissions | Fabricated quotation presented as from Dr. Howard's deposition—"No accreditation failure was ever cited against Dr. Pauliah"—attributed to 'Howard Dep. 27:1-3'; court found the quote does not appear in the transcript and was fabricated.
Counsel who attended the depositions still owe an independent transcript check on every AI-drafted quotation before signing a declaration.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Employment
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $5,000
- Procedural posture
- Following a summary judgment order, the court held a hearing under Fed. R. Civ. P. 56(h) to determine sanctions for a bad-faith declaration containing fabricated evidence.
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
Plaintiff admitted to using generative AI, but the specific tool was not named.
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.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.
- Train lawyers and staff to identify and verify generated legal content.