Incident Tracker / United States (federal)
Bevins v. Colgate-Palmolive Co., No. 2:25-cv-00576-MMB (E.D. Pa.)
·US District Court, Eastern District of Pennsylvania·US-FEDSanctions
In the Eastern District of Pennsylvania, Judge Baylson found attorney Nicholas L. Palazzo violated Rule 11 by citing two non-existent cases the court described as apparent AI hallucinations; the court struck his appearance with prejudice, ordered the memorandum served on the Pennsylvania and E.D. Pa. bars, and required him to inform his client. No fine was imposed.
- Court
- US District Court, Eastern District of Pennsylvania
- Date
- 2025-04-10
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- Plaintiff's counsel Nicholas L. Palazzo of DeFino Law Associates PC cited two cases in opposition briefs that the court could not locate and found do not exist on their face; the court described them as apparent AI hallucinations assembled from parts of real cases, though Palazzo made no statement about AI use and failed to file the affidavit required by the court's standing order on AI.
- Outcome
- Sanctions
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- State Bar of Pennsylvania and the Eastern District of Pennsylvania Bar (as worded in the order): Clerk directed to serve the memorandum and accompanying order on both bars; no further disposition confirmed (2025-04-10)
- Status
- Verified against listed sources
- Last checked
- 2026-09-04
What was fabricated or misused
- Tinch v. Video Indus. Servs., Inc., No. 1712 EDA 2018, 2019 WL 1396975, at *3 (Pa. Super. Ct. Mar. 27, 2019) — the court did not locate the case; the caption, Westlaw citation and case number pointed to different matters
- Burton v. Danek, No. 95-5560, 1997 WL 436713, at *8 (E.D. Pa. July 31, 1997) — the court did not locate the case; the Westlaw citation and case number pointed to different matters
What the court said
“The Court’s search did not locate this case or identify a plausible typographical error in the citation.”
“Again, the Court’s search did not locate this case or detect a possible typographical error in the citation.”
“Attorney Palazzo violated Fed. R. Civ. P. 11(b)(2) by submitting briefs to the Court that cited case law that did not support his stated propositions and which, on their face, do not exist.”
“Attorney Palazzo’s appearance in this case is hereby STRICKEN with prejudice due to his violation of Fed. R. Civ. P. 11(b)(2) and failure to submit an affidavit in accordance with this Court’s standing order.”
Timeline
- Bevins filed the product-liability complaint in Philadelphia County.
- Colgate-Palmolive removed the action to federal court.
- Counsel filed opposition briefs containing the Tinch and Burton citations.
- Court ordered counsel to show cause and produce the cited opinions.
- Counsel filed a memorandum, but no affidavit or copies of the opinions.
- Court struck counsel's appearance and ordered service on two bars.
Why this case matters
Bevins is a useful contrast to Benjamin and Dehghani because Judge Baylson did not find an admission of AI use; he treated the citations as apparent hallucinations assembled from real fragments and tied the sanction to both Rule 11 and his standing AI order. The remedy was nonmonetary but serious: counsel's appearance was stricken with prejudice and the clerk was told to send the order to two bars. That makes the record about court-controlled practice rights, not only fines.
Practice note
Counsel appearing before a judge with an AI standing order should file the required affidavit and verify each citation before filing. A response to an order to show cause should include the requested affidavit and copies of the opinions, or a direct explanation that they cannot be produced. Mixed case names, docket numbers and Westlaw cites should stop filing until resolved.
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, “Bevins v. Colgate-Palmolive Co., No. 2:25-cv-00576-MMB (E.D. Pa.)”, safelegalai.com/tracker/bevins-v-colgate-palmolive (accessed 2026-10-07). Data: CC BY 4.0.