Progressive Northern Insurance Company v. Tony Pete Flores, et al.
D. Nevada · Jun 18, 2026
- Jurisdiction
- federal
- Court
- D. Nevada
- Record ID
- progressive-northern-insurance-company-v-tony-pete-flores-et-al-2026-06-18
- Observed outcome
- The Court issued a formal warning to counsel and denied the Plaintiff's request for attorney's fees as moot.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court issued a formal warning to defense counsel regarding the submission of AI-generated content containing fabricated citations. The Court characterized this as a 'first and final warning,' noting that future failures to verify AI-generated filings could lead to sanctions or disciplinary proceedings. The Court denied the plaintiff's request for attorney's fees due to a failure to properly establish the legal authority for the request.
The Court reasoned that counsel's submission of unverified AI-generated content violated professional standards of competence, diligence, and candor. It noted that while fees were potentially warranted, the Plaintiff failed to specify the legal authority (Rule 11, 28 U.S.C. § 1927, or inherent power) or demonstrate compliance with procedural requirements for such an award.
This case highlights the judiciary's increasing focus on the duty of competence and candor when using AI. It serves as a reminder that even when underlying motions are withdrawn, courts may exercise their inherent power to address and warn counsel regarding the submission of fabricated legal authorities.
Failure modes and consequences
- Fabricated Case Law
- Inaccurate Citations
- Failure To Verify AI Generated Content
- Fake Citations
- Fabricated Quotes
- Other
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- The Court addressed a motion to strike (ECF No. 107) filed by the Plaintiff in response to the Defendants' motions for sanctions (ECF Nos. 100, 101). The Defendants subsequently withdrew their motions for sanctions. The Court denied the motion to strike as moot.
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 court refers to AI-generated content without naming a specific tool.
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
- Implement mandatory verification protocols for all AI-generated legal citations and quotes.
- Ensure all filings are reviewed by human counsel to confirm the existence and accuracy of cited authorities.
- Establish clear internal procedures for verifying the accuracy of AI-assisted research before submission to the court.
- When seeking sanctions for opposing counsel's AI-related misconduct, clearly identify the specific legal authority (e.g., Rule 11) and satisfy all procedural prerequisites.