Wayne K. Smith, Sr. v. Polk County, et al.
W.D. North Carolina · Jun 3, 2026
- Jurisdiction
- federal
- Court
- W.D. North Carolina
- Record ID
- wayne-k-smith-sr-v-polk-county-et-al-2026-06-03
- Observed outcome
- The court denied the motion for relief from judgment and ordered the plaintiff's counsel to show cause regarding potential sanctions for violating the court's Standing Order on AI.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated_legal_citations
- Failure_to_comply_with_local_rules
- Failure_to_file_mandatory_ai_certification
- Fake Citations
- Fabricated Quotes
- Civil Rights
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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
The court noted the defendants' contention that the brief was drafted using artificial intelligence.
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.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.