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HomeCasesState National Insurance Company, Inc. v. Damon Treadwell, et al.
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Corpus matter record

State National Insurance Company, Inc. v. Damon Treadwell, et al.

N.D. Alabama · Mar 26, 2026

AL / federalEditorial impact: highfake citationsfabricated quotescontracttrialProfessional
Direct answer

What happened in this matter?

The court sanctioned attorney Edward Eugene May, II with a public reprimand for submitting filings containing fabricated case law generated by ChatGPT and OpenCase. The court determined the attorney violated Rule 11 by failing to perform a reasonable inquiry into the accuracy of his legal citations, despite the attorney's admission of fault and apology.

Why the court cared
The court reasoned that Rule 11 imposes an objective standard of reasonable inquiry that does not require subjective bad faith. It concluded that presenting fabricated quotations as legal contentions constitutes an extreme dereliction of professional responsibility, necessitating a public sanction to deter future misconduct and maintain the integrity of the judicial system.
Why it matters now
A public reprimand follows ChatGPT fabrications even when admitted — ban consumer tools and require source-pull verification.

Why this matter is tracked

In a contract dispute, attorney Edward Eugene May, II submitted a filing containing two fabricated legal quotations attributed to Nishimatsu Construction Co. v. Houston National Bank and Whelan v. Abell. The court discovered the fabrications during its own review. Mr. May admitted to using ChatGPT and OpenCase to draft the filing and failing to verify the accuracy of the citations. The court found this conduct violated Federal Rule of Civil Procedure 11(b)(2) by presenting legal contentions not warranted by existing law. Consequently, the court issued a public reprimand, ordered the attorney to provide copies of the sanctions order to clients and opposing counsel in all pending cases, and directed the order be published in the Federal Supplement.

Operational lesson

A public reprimand follows ChatGPT fabrications even when admitted — ban consumer tools and require source-pull verification.

Record details

AlabamaSingle-state evidence scope
Explore ALOpen its source-linked jurisdiction page and related matters.
CourtN.D. Alabama
Jurisdictionfederal
Circuit11th Circuit
DateMar 26, 2026
CH
AI toolChatGPT, OpenCase
Party typeLawyer
OutcomePublic reprimand and mandatory distribution of the sanctions order to clients and opposing counsel in all pending cases, with the order directed for publication in the Federal Supplement.
Known amountNot recorded
Professional sanctionPublic reprimand and mandatory disclosure of the sanctions order to clients and opposing counsel in all pending cases.
Attribution boundary

What the record establishes about AI use

admitted

Attorney admitted using ChatGPT and OpenCase.

Procedural posture

Sanctions order issued following a show-cause hearing regarding Rule 11 violations.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

2 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Filing attributed a quoted passage to Nishimatsu Construction Co. v. Houston National Bank; the court searched the opinion and other sources and found the quotation does not exist; attorney admitted AI use and lack of diligence.
  2. Fabricated: Case Law | Filing attributed a quoted sentence to Whelan v. Abell; the court found no such quotation in that opinion or elsewhere and concluded the sentence was fabricated by AI.

Questions this record answers

What happened in State National Insurance Company, Inc. v. Damon Treadwell, et al.?
The court sanctioned attorney Edward Eugene May, II with a public reprimand for submitting filings containing fabricated case law generated by ChatGPT and OpenCase. The court determined the attorney violated Rule 11 by failing to perform a reasonable inquiry into the accuracy of his legal citations, despite the attorney's admission of fault and apology.
Why does State National Insurance Company, Inc. v. Damon Treadwell, et al. matter for legal AI risk?
A public reprimand follows ChatGPT fabrications even when admitted — ban consumer tools and require source-pull verification.
What does the public record establish about State National Insurance Company, Inc. v. Damon Treadwell, et al.?
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.
Which source supports this State National Insurance Company, Inc. v. Damon Treadwell, et al. 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.

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