Incident Tracker / United States (federal)
Aguilar v. The Crawford Group, Inc., No. 1:25-cv-12395-AK (D. Mass. 2026)
·United States District Court for the District of Massachusetts·US-FEDSanctions
In Massachusetts federal court, Judge Angel Kelley sanctioned California-barred counsel under Rule 11 for fictitious and misattributed citations across three briefs. His firm must pay the Enterprise defendants' fees and costs, capped at $10,000, and the court revoked his pro hac vice admission. Local counsel was not sanctioned but was reminded of his supervisory duties.
- Court
- United States District Court for the District of Massachusetts
- Date
- 2026-09-25
- Who used the AI
- Lawyer
- AI tool
- AI (unspecified enterprise-level tool)
- Conduct
- Pro hac vice counsel for the plaintiff filed three opposition briefs over several months containing a non-existent case, a fictitious Westlaw citation, quotations the cited cases do not contain and authorities cited for propositions they do not state. He admitted using AI to draft one brief, saying he believed the enterprise-level version he used did not hallucinate.
- Outcome
- Sanctions
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-05
What was fabricated or misused
- A non-existent case cited in the opposition to one motion to dismiss (Dkt. 97 at 19)
- A quotation attributed to Federal Deposit Insurance Corp. v. Jones with a fictitious Westlaw citation (Dkt. 51 at 12)
- Rodriguez v. Doral Mortgage Corp., 57 F.3d 1168 (1st Cir. 1995), cited six times for a proposition it does not stand for, then repeated in a later brief
- Glassman v. Computervision Corp., 90 F.3d 617 (1st Cir. 1996), cited for a non-existent quote
- Green Mountain Ins. Co., 484 Mass. 222 (2020), and Citizens Insurance Co. of America v. Federated Mutual Insurance Co., 448 Mich. 225 (1995), cited for quotations they do not contain
- Moore v. GEICO General Insurance Co. described as a case the defendants cited, with a fictitious citation
What the court said
“Lindemann admitted to using AI to draft the Strike Opposition, explaining that he believed that the enterprise-level version of AI software he was using did not hallucinate cases”
“There is no rule against the use of AI in researching and drafting legal papers, but it must be utilized responsibly. The use of AI does not diminish an attorney’s professional and ethical obligations under Rule 11.”
“Here, whether AI was used or not, Lindemann did not confirm the truthfulness of his citations.”
“The Court revokes Attorney Lindemann’s pro hac vice status.”
Timeline
- Court granted the California-barred lawyer's pro hac vice admission.
- Enterprise defendants moved for sanctions over the opposition to their motion to strike.
- Counsel responded to the court's order to show cause and admitted using AI on one brief.
- Court granted the sanctions motion, imposed fees and costs capped at $10,000 and revoked pro hac vice status.
Why this case matters
The order rejects two defences that recur in the tracker. Counsel said an earlier draft had been filed by mistake and that the enterprise version of his AI tool did not hallucinate; the court found errors in three briefs filed over months, and treated the five months before he admitted carelessness as a lack of candour. Revoking pro hac vice admission removes an out-of-state lawyer from the case entirely, a heavier consequence than the fee award.
Practice note
Out-of-state counsel admitted pro hac vice should verify every citation and quotation before filing, whatever AI product the firm licenses. Local counsel should review those filings, because the court reminded local counsel of his duty to supervise even though he was not sanctioned. A brief withdrawn because of bad citations should be explained to the court promptly.
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, “Aguilar v. The Crawford Group, Inc., No. 1:25-cv-12395-AK (D. Mass. 2026)”, safelegalai.com/tracker/aguilar-v-crawford-group (accessed 2026-10-05). Data: CC BY 4.0.