Incident Tracker / United States (federal)
Adams v. Matrix Providers, No. 1:23-cv-01996 (D. Colo.)
·US District Court for the District of Colorado·US-FEDFine
The US District Court for the District of Colorado fined counsel Ms Pearson USD 1,000 after her brief cited a nonexistent case and attributed a quotation to Justice Scalia from an opinion dated 2020, four years after his death. Judge Sweeney's order is on CourtListener RECAP; the available summary does not record whether counsel admitted using generative AI.
- Court
- US District Court for the District of Colorado
- Date
- 2026-08-27
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- Counsel Ms Pearson filed a brief containing a phantom citation and a quotation attributed to Justice Scalia from a 2020 opinion, although Justice Scalia died in 2016.
- Outcome
- Fine
- Penalty
- US$1,000
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
What was fabricated or misused
- Ricks v. Starbucks Corp., No. 21-cv-01386, 2023 WL 8872476, at *6 (D. Colo. Dec. 22, 2023) — court and opposing counsel could not locate it; counsel later said she had no copy
- language from a 2020 Supreme Court decision attributed to Justice Scalia — misattributed because Justice Scalia died in 2016
- numerous citations that do not stand for the proposition for which they are cited — the order did not list each citation
What the court said
“Ricks v. Starbucks Corp., No. 21-cv-01386, 2023 WL 8872476, at *6 (D. Colo. Dec. 22, 2023), see ECF No. 88 at 18, which neither the Court nor counsel for Defendant was able to locate.”
“The Court believes that the inclusion of the Ricks case in Plaintiff’s briefing was likely only possible because Ms. Pearson used artificial intelligence (AI) to complete her legal research.”
“Whether these misstatements were the result of the use of an AI legal search, or simply poor and unexacting legal judgment, is unclear.”
“the Court hereby sanctions Plaintiff’s counsel, Nicole Pearson, in the amount of $1,000 pursuant to Rule 11(c)(1), Local Rule 83.1(e), and CNS Civ. Practice Standard 1.1(c).”
Timeline
- At summary-judgment hearing, court identified unverifiable and inaccurate citations.
- Counsel emailed that she had no copy of Ricks.
- Court ordered counsel to show cause over briefing errors and courthouse photos.
- Court denied post-judgment motions and imposed a $1,000 sanction.
Why this case matters
Adams is a Colorado federal counterpart to Salloum’s same-day state appellate warning, but the sanction rested on counsel’s broader rule compliance problems as well as bad citations. The order is narrower than Booker because the court did not find an admitted AI denial; it said the source of misstatements was unclear. Its record value is that one phantom case triggered scrutiny of briefing, courthouse-photo rules and practice standards, ending in a $1,000 sanction payable by counsel.
Practice note
Counsel should not delegate filing review without a final citation audit under their own name. For each authority, keep a copy or database link, confirm the quoted language and holding, and check local rules before the hearing. If the court requests a cited case, produce it immediately or correct the filing.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Adams v. Matrix Providers, No. 1:23-cv-01996 (D. Colo.)”, safelegalai.com/tracker/adams-v-matrix-providers (accessed 2026-10-07). Data: CC BY 4.0.