United States of America v. Lorenzio Reshaud Simmons
E.D. North Carolina · Oct 3, 2025
- Jurisdiction
- federal
- Court
- E.D. North Carolina
- Record ID
- united-states-of-america-v-lorenzio-reshaud-simmons-2025-10-03
- Observed outcome
- The court issued a warning to counsel and permitted the filing of a corrected sentencing memorandum.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated Case Law
- Misrepresented Legal Authority
- False Quotations
- Lack Of Human Verification
- Fake Citations
- Fabricated Quotes
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Sentencing memorandum phase in a federal criminal case.
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 AI to frame arguments.
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.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Read the linked source and subsequent docket history before relying on this record for legal work.