Shields v. First Financial
Tennessee · Nov 21, 2025
What happened in this matter?
The court issued a formal warning to plaintiff's counsel regarding the inclusion of multiple fabricated or incorrect legal citations in court filings. The judge noted that these errors are characteristic of AI-generated research and ordered counsel to verify the accuracy of all future legal citations.
- Why the court cared
- Fabricated: Case Law | Doe v. Roe, No. M2018-01746-COA-R3-CV (Tenn. Ct. App. 2019) in Plaintiffs Motion for Limited Discovery Pg. 5. There is no Doe v. Roe case in the Tennessee Court of Appeals in 2019 and No. M2018-01746-COA-R3-CV returns Jones v. Jones, No. M201801746COAR3CV, 2019 WL 1036077 (Tenn. Ct. App. Mar. 5, 2019). || Fabricated: Case Law | Nandigam Neurology, PLC v. Beavers, No. M2021-01280-COA-R9-CV, 2022 WLE 1512346, at *5 (Tenn. Ct. App. May 13, 2022) in Plaintiffs Response to Defendant’s Motion to Compel Pg. 2. There is a Nandigam Neurology, PLC v. Beavers, 639 S.W.3d 651 (Tenn. Ct. App. 2021), but neither 2022 WL 1512346 nor No. M2021-01280-COA-R9-CV return any case in Tennessee. || Fabricated: Legal Norm || Fabricated: Case Law | Doe v. Roe, 477 S.W.3d 321, 326 (Tenn. Ct. App. 2015) in /<7 Pg. 4. There is no Doe v. Roe in the Tennessee Court of Appeals in 2015 and the reporter number corresponds to Ford v. State, 477 S.W.3d 321 (Tex. Crim. App. 2015). || Fabricated: Case Law | Schultz v. Davis, 495 S.W.3d 821, 827 (Tenn. 2016) in Plaintiffs Motion to Amend Pg. 4. There is no Schultz v. Davis case in 2016 and the reporter number corresponds to State v. Dixon, 495 S.W.3d 812 (Mo. Ct. App. 2016). || Fabricated: Case Law | Vincent v. Yelverton, 194 F. App'x 303, 307 (6th Cir. 2006) in Id Pg. 4. There is no Vincent v. Yelverton in the 6th Circuit in 2006 and the reporter number corresponds to United States v. Younes, 194 F. App'x 302 (6th Cir. 2006)
- Why it matters now
- Cross-check every reporter and docket number against primary databases before signing the brief; parallel-citation swaps are the tell.
Why this matter is tracked
In Shields v. First Financial, the Sixth Circuit Court for Davidson County, Tennessee, issued an order granting the plaintiff's motion to amend the complaint. Within the same order, the court cautioned plaintiff's counsel regarding multiple incorrect legal citations found across several filings, including motions for limited discovery, responses to motions to compel, and motions to amend. The court identified specific instances where cited cases did not exist or where reporter numbers corresponded to unrelated cases from other jurisdictions. The court noted that these citation errors are characteristic of artificial intelligence use and explicitly cautioned counsel to verify the accuracy of all legal citations in future filings, regardless of whether AI tools were utilized in the drafting process.
Cross-check every reporter and docket number against primary databases before signing the brief; parallel-citation swaps are the tell.
Record details
What the record establishes about AI use
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Order granting Plaintiff's Motion to Amend Complaint and issuing a judicial caution regarding citation accuracy.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Doe v. Roe, No. M2018-01746-COA-R3-CV (Tenn. Ct. App. 2019) in Plaintiffs Motion for Limited Discovery Pg. 5. There is no Doe v. Roe case in the Tennessee Court of Appeals in 2019 and No. M2018-01746-COA-R3-CV returns Jones v. Jones, No. M201801746COAR3CV, 2019 WL 1036077 (Tenn. Ct. App. Mar. 5, 2019).
- Fabricated: Case Law | Nandigam Neurology, PLC v. Beavers, No. M2021-01280-COA-R9-CV, 2022 WLE 1512346, at *5 (Tenn. Ct. App. May 13, 2022) in Plaintiffs Response to Defendant’s Motion to Compel Pg. 2. There is a Nandigam Neurology, PLC v. Beavers, 639 S.W.3d 651 (Tenn. Ct. App. 2021), but neither 2022 WL 1512346 nor No. M2021-01280-COA-R9-CV return any case in Tennessee.
- Fabricated: Legal Norm
- Fabricated: Case Law | Doe v. Roe, 477 S.W.3d 321, 326 (Tenn. Ct. App. 2015) in /<7 Pg. 4. There is no Doe v. Roe in the Tennessee Court of Appeals in 2015 and the reporter number corresponds to Ford v. State, 477 S.W.3d 321 (Tex. Crim. App. 2015).
- Fabricated: Case Law | Schultz v. Davis, 495 S.W.3d 821, 827 (Tenn. 2016) in Plaintiffs Motion to Amend Pg. 4. There is no Schultz v. Davis case in 2016 and the reporter number corresponds to State v. Dixon, 495 S.W.3d 812 (Mo. Ct. App. 2016).
- Fabricated: Case Law | Vincent v. Yelverton, 194 F. App'x 303, 307 (6th Cir. 2006) in Id Pg. 4. There is no Vincent v. Yelverton in the 6th Circuit in 2006 and the reporter number corresponds to United States v. Younes, 194 F. App'x 302 (6th Cir. 2006)
Questions this record answers
- What happened in Shields v. First Financial?
- The court issued a formal warning to plaintiff's counsel regarding the inclusion of multiple fabricated or incorrect legal citations in court filings. The judge noted that these errors are characteristic of AI-generated research and ordered counsel to verify the accuracy of all future legal citations.
- Why does Shields v. First Financial matter for legal AI risk?
- Cross-check every reporter and docket number against primary databases before signing the brief; parallel-citation swaps are the tell.
- What does the public record establish about Shields v. First Financial?
- 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.
- Which source supports this Shields v. First Financial summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.