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Courts on AI / Fabricated or misquoted citations

Gentry v. Thompson

United States District Court for the Eastern District of Louisiana · Federal district courts · LA · · 2026 WL 787563 · No. 25-1260 · order

On 2026-03-20, U.S. District Court for the Eastern District of Louisiana personally sanctioned counsel $1,250 and formally admonished him after he admitted using ChatGPT without checking nine hallucinated cases. Counsel submitted a brief with The brief cited nine hallucinated cases generated through ChatGPT that counsel admitted he had not checked.

Disposition
The court found Rule 11 violations and imposed $250 on Jalen Harris and $1,000 on James Roquemore.
Recorded conduct
Defense counsel's memorandum supporting a Rule 12(b)(6) motion contained nine nonexistent case citations generated through ChatGPT and not checked before filing. — outcome: fine; actor: lawyer; $1,250
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

problem of attorneys’ improper use of A.I. cases on Westlaw but admitted that he eventually resorted to ChatGPT. Mr. Harris took full responsibility for his misuse Both Mr. St. Raymond and City Attorney Gipson outlined of generative A.I. and conceded that he did not check the the actions the City Attorney's Office has taken to citations that ChatGPT had provided, nor did he attempt to combat the future misuse of A.I. Specifically, the City read the nine hallucinated cases that he cited in the brief. DANIEL GENTRY v. CALVIN THOMPSON ET AL., Slip Copy (2026) Attorney's Litigation Division called a department-wide meeting immediately after the Court issued the Order to Show Cause in this matter, and Ms. Gipson and her staff CONCLUSION are currently in the process of developing a written policy concerning the use of generative A.I. in the City Attorney's Accordingly, Office. Further, Mr. Harris and Mr. Roquemore attended a Thomson Reuters seminar about proper and improper uses IT IS HEREBY ORDERED that under Federal Rule of Civil of A.I. in legal practice. Ms. Gipson also emphasized the Procedure Rule 11, Jalen Harris is personally sanctioned for importance

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