Woodward Harbor L.L.C., et al. v. City of Mandeville

What the court wrote

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

III. ANALYSIS The problem of AI-fabricated case citations is well-documented throughout the judiciary, including in this circuit. See, e.g., Fletcher v. Experian Info. Sols., Inc., 2026 WL 456842, at *2 (5th Cir. Feb. 18, 2026) (“Regrettably, despite numerous news stories, CLE presentations, scholarly articles, and judicial entreaties, AI-hallucinated case citations have increasingly become an even greater problem in our courts, and the problem shows no sign of abating.”) (collecting cases). “To ethically use generative AI in the practice of law—which we do not dispute can be helpful if done properly and carefully—a lawyer must ‘ensure that the legal propositions and authority generated are trustworthy.’” Id. (citation omitted). “Failure to do so ‘abdicate[s] one’s duty, waste[s] legal resources, and lower[s] the public’s respect for the legal profession and judicial proceedings.’” Id. (citation omitted) (alteration in original). In this case, one attorney has candidly admitted to the Court that he alone was responsible for using generative AI technology to draft the opposition motion without verifying the accuracy of the citations.15 In doing so, Mr. Walker failed in his obligation to conduct a reasonable inquiry into the law and facts underlying Plaintiff’s brief. See City of Bogalusa, 168 F.3d at 241. The Court thus finds that Mr. Walker violated Rule 11(b)(2) by citing to fabricated AI-generated cases and by “fail[ing] to 15 ECF No. 104-1. 5 Case 2:23-cv-05824-BSL-EJD Document 117 Filed 03/05/26 Page 6 of 8

Authorities cited in the passage: Wood v. City of Utica · Qutb v. Ramsey · Plaintiffs cited a non-existent case 'Wood v. City of Utica' to support a legal proposition · Plaintiffs cited 'Qutb v. Ramsey' with an incorrect reporter and circuit · Fletcher v. Experian Info. Sols · Rule 11(b)(2)