Rasheem Carter, et al. v. UZGlobal LLC, et al.
D. New Mexico · May 1, 2026
- Jurisdiction
- federal
- Court
- D. New Mexico
- Record ID
- rasheem-carter-et-al-v-uzglobal-llc-et-al-2026-05-01
- Observed outcome
- The court imposed a $1,000 fine, required self-reporting to state bar disciplinary boards, mandated AI-related CLE, and authorized the opposing party to move for attorney fees and costs.
- Known monetary consequence
- $1,000
Why this matter warrants attention
The court sanctioned attorney Maxey Scherr for Rule 11 violations after she filed briefs containing sixteen AI-hallucinated cases. The court ordered a $1,000 fine, mandatory bar reporting, and completion of AI-focused CLE, while also permitting the opposing party to move for recovery of attorney fees and costs incurred due to the misconduct.
The court determined that submitting AI-hallucinated cases is objectively unreasonable. Under Rule 11, the signing attorney is responsible for the content of filings regardless of whether an associate drafted them. The court noted that the attorney had received prior notice of a potentially fake citation but failed to review subsequent filings, demonstrating a lack of objectively reasonable effort to verify legal authorities.
This case underscores that attorneys cannot delegate Rule 11 verification duties to associates or AI tools. It highlights the severe consequences of failing to perform a cursory review of filings, even after receiving notice of potential citation errors.
Failure modes and consequences
- Fake Citations
- Bar Referral
- Tort
- Trial
- Monetary
- Professional
- AI attribution
- Implied
- Recorded tool
- Unidentified
- Known monetary consequence
- $1,000
- Procedural posture
- Order imposing sanctions following the court's issuance of two Orders to Show Cause regarding the use of non-existent case law in multiple filings.
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
Plaintiffs believe AI was used but do not know the specific program.
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 manual verification protocols for all legal citations in every filing.
- Establish firm-wide policies prohibiting the use of unverified AI-generated legal research.
- Conduct immediate internal audits of all pending filings upon receiving notice of potential citation inaccuracies.
- Ensure signing attorneys personally review all citations in briefs drafted by associates or AI tools.