A federal judge in Massachusetts has revoked a California lawyer's pro hac vice status for filing briefs with fictitious and misleading citations, and ordered his firm to pay the other side's fees up to $10,000. The order is dated September 25, 2026. It was reported on October 16, and its fee deadline falls on October 23. Court order (D. Mass., Doc. 155)
What the court ordered
In Aguilar v. The Crawford Group, Inc., No. 1:25-cv-12395-AK, Judge Angel Kelley granted the defendants' motion for sanctions under Federal Rule of Civil Procedure 11 and imposed sanctions on the court's own initiative. Docket on CourtListener
The Lindemann Law Firm must pay the reasonable fees and costs the Enterprise Defendants spent answering the flawed opposition, litigating the sanctions motion and answering a second opposition. The order caps the amount at $10,000.
Attorney Blake Lindemann's pro hac vice status is revoked. Massachusetts local counsel stays on as plaintiff's counsel.
The parties must file a joint notice on fees by October 23, 2026. A status conference is set for November 9, 2026.
What the briefs got wrong
Three of the plaintiff's oppositions contained citation errors. The first, an opposition to a motion to strike, was filed less than five hours after the motion, according to the order. It cited a First Circuit case six times for a proposition the case does not support, attributed a quotation to a case with a fictitious Westlaw citation, and quoted cases for language they do not contain.
Later briefs repeated the problem. One cited a case the court could not find after searching Westlaw, Lexis and Bloomberg. Another described the defendants as citing a case they never cited.
The court did not name the software. Lindemann admitted using AI to draft the first opposition and explained that he believed the enterprise-level version of the AI software he was using did not hallucinate cases. The court treated the tool question as secondary: "whether AI was used or not, Lindemann did not confirm the truthfulness of his citations."
Why the court rejected the explanations
Lindemann blamed a rushed filing before vacation, an earlier draft filed by mistake, and a bout of influenza. The court was not persuaded. He returned from vacation a week before the opposition was due, had asked for and received an extension during his illness, and never produced the "correct" draft.
Two points in the order matter beyond this case.
Bad faith is not required. The court applied First Circuit law that a "pure heart no longer excuses an empty head." Failing to check the work is enough.
Notice changes the analysis. The defendants emailed about the errors and then filed the sanctions motion. Later briefs still contained false or misleading citations. The court read that as a pattern, not carelessness.
Mitigation counted for something. Lindemann adopted citation-verification procedures and took CLE credits on AI ethics, which weighed toward a "measured" sanction. It did not excuse the conduct.
The local counsel point
The court declined to sanction local counsel because Lindemann admitted he alone was responsible for the filings. It still reminded local counsel of his duty to assist and supervise pro hac counsel, citing authority that local counsel is responsible to the court for the conduct of the case. A New York Daily Record analysis published October 16 warns that other courts may not stop at a reminder. NY Daily Record, October 16
What a firm should take from it
A vendor tier is not a verification step. "Enterprise" describes contract and security terms. It says nothing about whether each citation exists and supports the sentence it sits under. Keep a named person responsible for checking every authority before filing. The pre-filing verification checklist and the citation verification protocol are starting points.
Supervision reaches across the firm boundary. If you serve as local counsel, agree in writing who checks authorities and how, and price that review into the engagement. The Rule 5.3 supervision guide covers the duty.
Correct fast. The sanction grew from the delay and from filings that kept repeating errors after notice. If opposing counsel flags a citation, check every brief you have filed in the matter.
For the wider pattern, see the AI legal risk case tracker, the AI sanctions tracker and the original warning in Mata v. Avianca. For what happens after a fabricated citation reaches a court, read what happens next.
Operational information, not legal advice. Order and docket checked October 20, 2026. The facts above come from the court's September 25 order and its docket; we did not review the underlying briefs.
Questions and answers
What did the court do in Aguilar v. Crawford Group?
On September 25, 2026, Judge Angel Kelley of the District of Massachusetts granted a Rule 11 sanctions motion, revoked California attorney Blake Lindemann's pro hac vice status and ordered his firm to pay the defendants' related fees and costs, capped at $10,000.
Did the court find that AI caused the fake citations?
Lindemann admitted using AI to draft one brief. The court did not name the tool and said that, whether AI was used or not, he failed to confirm his citations.
Is bad faith required for Rule 11 sanctions in this court?
No. The order applies First Circuit law that bad faith is not a prerequisite to a Rule 11 sanction. It also found a pattern because errors continued after the defendants gave notice.
Was local counsel sanctioned?
No. The court relied on Lindemann's admission that he alone was responsible, but reminded local counsel of his continuing duty to assist and supervise pro hac counsel.
What happens next in the case?
The parties must file a joint notice on the amount of fees by October 23, 2026, and the court set a status conference for November 9, 2026.
Operational information, not legal advice. The order and docket were rechecked October 20, 2026. This update uses AI-assisted research and editing and is published under the byline of Manu Ayala.