Progressive Northern Insurance Company v. Tony Pete Flores, et al.
D. Nevada · Jul 13, 2026
- Jurisdiction
- federal
- Court
- D. Nevada
- Record ID
- progressive-northern-insurance-company-v-tony-pete-flores-et-al-2026-07-13
- Observed outcome
- The motion to strike was denied as moot because the underlying motions were withdrawn; the court issued a formal warning to counsel regarding future AI-generated submissions.
- Known monetary consequence
- $0
Why this matter warrants attention
The court issued a formal warning to defense counsel regarding the submission of AI-generated filings containing fabricated citations and inaccurate quotations. The court found the conduct violated professional standards but denied the plaintiff's request for fees and a filing bar due to procedural failures in the motion to strike.
The court reasoned that counsel's failure to verify AI-generated content breached professional conduct rules (competence, diligence, candor). It denied fees because the plaintiff failed to specify the legal authority for the motion or comply with Rule 11 requirements.
This case highlights the judicial expectation that counsel must independently verify all AI-generated citations and quotations. It serves as a reminder that even when motions are withdrawn, courts may issue formal warnings regarding the underlying professional conduct.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Contract
- Trial
- Warning
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $0
- Procedural posture
- The court issued an order addressing a motion to strike (ECF No. 107) filed by the plaintiff in response to the defendants' motions for sanctions (ECF Nos. 100, 101).
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 quotations before filing.
- Ensure all motions for sanctions or fees clearly identify the specific legal authority (e.g., Rule 11, 28 U.S.C. § 1927) and satisfy all procedural prerequisites.
- Document internal corrective measures taken to address AI-related errors to demonstrate good faith to the court.