Robert Dastou v. Kathryn Holmes, No. 2381CV02212 (Mass. Super. Ct.)

sanctions

A Massachusetts Superior Court sanctioned a defense attorney who used ChatGPT to 'format' filings, producing motions in limine and jury instructions riddled with hallucinated cases, a fake quotation, and a fictitious legal doctrine. The court accepted her agreement not to bill the client for the affected work and ordered her to complete a CLE course.

Date of decision/order: 2025-07-16
Court: Massachusetts Superior Court
Jurisdiction: US-STATE
AI tool: ChatGPT
Conduct: Defendant's counsel filed motions in limine and proposed jury instructions containing citations to nonexistent cases, a fabricated quotation, and a fictitious legal concept after using ChatGPT to 'format' her filings. The court held a hearing on the suspected misuse of generative AI.
Consequence: See outcome

Sources

Robert Dastou v. Kathryn Holmes (Mass. Super. Ct., 16 Jul 2025), Findings, Rulings and Order Imposing Sanctions — CourtListener

Cite this incident

SafeLegalAI Global Legal AI Incident Tracker, "Robert Dastou v. Kathryn Holmes, No. 2381CV02212 (Mass. Super. Ct.)", safelegalai.com/tracker/dastou-v-holmes (accessed 2026-07-16). Data: CC BY 4.0.