United States of America v. Lorenzio Reshaud Simmons
E.D. North Carolina · Oct 3, 2025
What happened in this matter?
The court issued a warning to defense counsel and allowed the filing of a corrected sentencing memorandum after counsel submitted a brief containing multiple fabricated case citations and false quotations generated by an unidentified AI tool.
- Why the court cared
- The court reasoned that the filing violated Local Criminal Rules and the Rules of Professional Conduct by presenting false statements of law without verifying the existence or accuracy of cited authorities, noting that such errors impose an undue burden on the court's time and resources.
- Why it matters now
- This case illustrates the risks of using AI for legal drafting without verification. It serves as a precedent for judicial responses to AI-generated hallucinations, emphasizing that counsel bears full responsibility for the accuracy of all citations and quotes submitted to the court.
Why this matter is tracked
In a federal sentencing memorandum, defense counsel submitted a filing containing at least 11 instances of fabricated case law, misrepresented citations, and false quotations. The court identified that the memorandum bore hallmarks of AI generation, noting that the AI invented case names, misattributed holdings to incorrect circuits, and fabricated quoted language. Counsel acknowledged using AI to frame arguments and failing to verify the output before filing. The court characterized the conduct as a violation of local rules and professional conduct standards regarding the duty to provide accurate legal authority. The court issued a warning to counsel and permitted the filing of a corrected sentencing memorandum, emphasizing the risks of relying on unverified AI-generated legal research.
This case illustrates the risks of using AI for legal drafting without verification. It serves as a precedent for judicial responses to AI-generated hallucinations, emphasizing that counsel bears full responsibility for the accuracy of all citations and quotes submitted to the court.
Record details
What the record establishes about AI use
Counsel admitted to using AI to frame arguments.
Sentencing memorandum phase in a federal criminal case.
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 | Memorandum cited 'United States v. Hazel, 696 F.3d 473, 478 (4th Cir. 2012)' — court found no such Fourth Circuit case (citation appears fabricated).
- Fabricated: Case Law | Memorandum cited 'United States v. Angel, 102 F.3d 1066 (4th Cir. 1996)' for a quoted rule; court found no such Fourth Circuit decision or matching quoted language.
- Misrepresented: Case Law | Memorandum cited 'United States v. Brehm, 442 F.3d 1291, 1293 (4th Cir. 2006)' and attributed the quote 'any uncertainty should be resolved in the defendant's favor.' The court noted the cited Brehm reference is to a different circuit and does not contain that quoted language.
- Misrepresented: Case Law | Memorandum cited 'United States v. Nealy, 232 F.3d 825, 829 (4th Cir. 2000)' for language about burdens the government cannot meet; court found the citation is to a different circuit and does not contain the asserted language.
- False Quotes: Case Law | Memorandum cited 'United States v. Edwards, 188 F.3d 230, 232 (4th Cir. 1999)' and quoted that packaging weight should not be included; court found Edwards does not contain that quoted language (false quotation).
- Misrepresented: Case Law | Memorandum cited 'United States v. Harrision, 918 F.2d 469, 473 (4th Cir. 1990)' for a statement that laboratory testing is more precise; court noted the correct case is in a different circuit (Fifth) and does not contain that quoted text.
Questions this record answers
- What happened in United States of America v. Lorenzio Reshaud Simmons?
- The court issued a warning to defense counsel and allowed the filing of a corrected sentencing memorandum after counsel submitted a brief containing multiple fabricated case citations and false quotations generated by an unidentified AI tool.
- Why does United States of America v. Lorenzio Reshaud Simmons matter for legal AI risk?
- This case illustrates the risks of using AI for legal drafting without verification. It serves as a precedent for judicial responses to AI-generated hallucinations, emphasizing that counsel bears full responsibility for the accuracy of all citations and quotes submitted to the court.
- What does the public record establish about United States of America v. Lorenzio Reshaud Simmons?
- 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 United States of America v. Lorenzio Reshaud Simmons 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.