In re BFI Waste Systems of Tennessee

What the court wrote

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

On July 30, 2026, the Court ordered several of plaintiff's attorneys to show cause why they should not be sanctioned-under either or both of Rule 11 of the Federal Rules of Civil Procedure and the Court's inherent authority-for filing a document at Doc. No. 293 that contained hallucinated quotations and misleading citations. ... Ringger has confirmed the Court's suspicion that a major factor in the deficiencies at Doc. No. 293-plus others that he identified (Doc. No. 328 at 6)-was the failure to check content generated through tools using artificial intelligence. ... The novel danger with artificial intelligence is how much easier a Rule 11 violation becomes when using it. Submitting false legal authority by conventional means requires either willfulness or a failure by multiple professionals involved in the preparation of a document. ... This is where Ringger fell short, with quotations that did not exist and with legal citations that gave the impression that an argument in his favor had support when it did not. This conduct must be swiftly addressed and deterred. For those reasons, Ringger must be sanctioned. ... Attorney Ringger has violated Rule 11 and is hereby publicly reprimanded through this order. Ringger also is assessed a monetary sanction of $1,500.00, payable to the Clerk of the Court within 30 days after entry of this order.

Authorities cited in the passage: Fed. R. Civ. P. 11 · Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023) · Safe Choice, LLC v. City of Cleveland, 2025 WL 2958211 (N.D. Ohio Oct. 17, 2025) · Rivera v. Triad Props. Corp., 829 F. Supp. 3d 983 (N.D. Ala. 2026) · Benjamin v. Costco Wholesale Corp., 779 F. Supp. 3d 341 (E.D.N.Y. 2025)