Rodney Herod v. Hobby Lobby Stores, Inc.
N.D. Texas · Jun 23, 2026
- Jurisdiction
- federal
- Court
- N.D. Texas
- Record ID
- rodney-herod-v-hobby-lobby-stores-inc-2026-06-23
- Observed outcome
- The court granted the defendant's motion for summary judgment, finding no genuine issue of material fact regarding the defendant's duty or liability.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
In Rodney Herod v. Hobby Lobby Stores, Inc., the plaintiff's counsel admitted to using generative AI to draft a response that included a fabricated case citation. The court identified the error during proceedings, and counsel filed a notice of errata. The court granted the defendant's motion for summary judgment on the merits of the underlying negligence claim.
The court noted that it was unable to locate the cited case and that counsel admitted at the hearing that the case did not exist and was generated by AI without verification.
This case serves as a reminder of the necessity for rigorous verification of all AI-generated legal research. It demonstrates how fabricated citations can undermine a party's credibility and legal arguments in federal court.
Failure modes and consequences
- Fake Citations
- Tort
- Trial
- None Adjudicated
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued a Memorandum Opinion and Order on June 23, 2026, granting the defendant's motion for summary judgment and denying the plaintiff's motion to amend the scheduling order.
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
Counsel admitted to using generative artificial intelligence.
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 case law citations generated by AI tools.
- Require counsel to certify that all authorities cited in pleadings have been independently verified for existence and accuracy.
- Conduct internal audits of legal research workflows to ensure compliance with local rules regarding AI usage.