Wayne K. Smith, Sr. v. Polk County, et al.
W.D. North Carolina · Jun 3, 2026
What happened in this matter?
The court ordered the plaintiff's counsel to show cause as to why she should not be sanctioned for failing to comply with the court's Standing Order Regarding the Use of Artificial Intelligence, specifically citing the inclusion of fabricated legal quotations and repeated failures to file mandatory AI-use certifications in multiple filings.
- Why the court cared
- The court reasoned that counsel's failure to provide an adequate explanation for fabricated quotations, combined with repeated failures to file timely AI-use certifications as required by the Standing Order, raised serious questions about counsel's conduct warranting a show cause order.
- Why it matters now
- This case highlights the judicial enforcement of standing orders requiring disclosure of AI use. It demonstrates that courts may treat fabricated legal citations as a serious procedural failure, regardless of whether counsel claims the underlying legal principles remain accurate.
Why this matter is tracked
In a civil rights action, the court denied the plaintiff's motion for relief from judgment and leave to file a third amended complaint. The court identified that the plaintiff's opening brief contained fabricated legal quotations and lacked required certifications regarding the use of artificial intelligence, violating the court's Standing Order. Counsel acknowledged the inaccuracies but failed to provide an adequate explanation for the origin of the fabricated citations or the repeated failure to file mandatory AI-use certifications. Consequently, the court admonished counsel and issued an order directing the plaintiff's counsel to show cause as to why she should not be sanctioned for failing to comply with the court's Standing Order regarding AI usage.
This case highlights the judicial enforcement of standing orders requiring disclosure of AI use. It demonstrates that courts may treat fabricated legal citations as a serious procedural failure, regardless of whether counsel claims the underlying legal principles remain accurate.
Record details
What the record establishes about AI use
The court noted the defendants' contention that the brief was drafted using artificial intelligence.
The court issued a Memorandum of Decision and Order denying the plaintiff's motion for relief from judgment and directing counsel to show cause regarding potential sanctions.
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.
- False Quotes: Case Law | Plaintiff's opening brief attributes a quotation to Board of County Commissioners v. Brown that does not appear verbatim in that decision; Court labels it a fabricated quotation and counsel acknowledges the inaccuracy.
- False Quotes: Case Law | Plaintiff's opening brief attributes a quotation to Laber v. Harvey that is a misquotation; counsel acknowledges the misquotation though contends the underlying principle is correct.
Questions this record answers
- What happened in Wayne K. Smith, Sr. v. Polk County, et al.?
- The court ordered the plaintiff's counsel to show cause as to why she should not be sanctioned for failing to comply with the court's Standing Order Regarding the Use of Artificial Intelligence, specifically citing the inclusion of fabricated legal quotations and repeated failures to file mandatory AI-use certifications in multiple filings.
- Why does Wayne K. Smith, Sr. v. Polk County, et al. matter for legal AI risk?
- This case highlights the judicial enforcement of standing orders requiring disclosure of AI use. It demonstrates that courts may treat fabricated legal citations as a serious procedural failure, regardless of whether counsel claims the underlying legal principles remain accurate.
- What does the public record establish about Wayne K. Smith, Sr. v. Polk County, 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 Wayne K. Smith, Sr. v. Polk County, 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.