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
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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 2026-09-05). Data: CC BY 4.0.