State National Insurance Company, Inc. v. Damon Treadwell, et al.
N.D. Alabama · Mar 26, 2026
- Jurisdiction
- federal
- Court
- N.D. Alabama
- Record ID
- state-national-insurance-company-inc-v-damon-treadwell-et-al-2026-03-26
- Observed outcome
- Public 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 monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
A public reprimand follows ChatGPT fabrications even when admitted — ban consumer tools and require source-pull verification.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Contract
- Trial
- Professional
- AI attribution
- Admitted
- Recorded tool
- ChatGPT, OpenCase
- Known monetary consequence
- Not recorded
- Procedural posture
- Sanctions order issued following a show-cause hearing regarding Rule 11 violations.
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
Attorney admitted using ChatGPT and OpenCase.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to ChatGPT; OpenCase output as to any other research input.