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Incident Tracker / United States (federal)

Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281 (E.D. Tex.)

·US District Court, Eastern District of Texas (Beaumont Division)·US-FEDSanctions

In the US District Court for the Eastern District of Texas, plaintiff's attorney Brandon Monk filed a brief with non-existent cases and fabricated quotations produced by the AI tool Claude, which he did not verify. Judge Marcia Crone ordered him to pay a $2,000 penalty into the court registry and complete a CLE course on generative AI.

Court
US District Court, Eastern District of Texas (Beaumont Division)
Date
2024-11-25
Who used the AI
Not recorded
AI tool
Claude (Anthropic)
Conduct
Plaintiff's counsel Brandon Monk filed a summary-judgment response citing non-existent cases and fabricated quotations attributed to real cases. He admitted using the AI tool Claude to draft the brief and failing to verify the output, and initially took no corrective action after opposing counsel identified the fake authorities.
Outcome
Sanctions
Penalty
US$2,000
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-11

What was fabricated or misused

  • Roca v. King’s Creek Plantation, LLC, 500 F. App’x 273, 276 (5th Cir. 2012) (unpublished) — no such case exists
  • Beets v. Texas Instruments, Inc., No. 94-10034, 1994 WL 714026, at *3 (5th Cir. Dec. 16, 1994) (unpublished) — no such case exists
  • Quotations attributed to Morales v. SimuFlite Training Int’l, Inc., 132 S.W.3d 603 (Tex. App.—Fort Worth 2004, no pet.) — not in the cited authority
  • Quotations attributed to White v. FCI USA, Inc., 319 F.3d 672 (5th Cir. 2003) — not in the cited authority
  • Quotations attributed to Burton v. Freescale Semiconductor, Inc., 798 F.3d 222 (5th Cir. 2015) — not in the cited authority
  • Quotations attributed to Texas Dep't of Human Servs. v. Hinds, 904 S.W.2d 629 (Tex. 1995) — not in the cited authority
  • Quotations attributed to Physio GP, Inc. v. Naifeh, 306 S.W.3d 886 (Tex. App.—Houston [14th Dist.] 2010, no pet.) — not in the cited authority
  • Quotations attributed to City of Midland v. O’Bryant, 18 S.W.3d 209 (Tex. 2000) — not in the cited authority
  • Quotations attributed to Roca v. King’s Creek Plantation, LLC, 500 F. App’x 273 (5th Cir. 2012) — from the hallucinatory case

What the court said

“Pending before the court is the question of whether Plaintiff’s counsel, Brandon Monk (“Monk”), should be sanctioned for submitting a response brief to the court that includes case cites generated by artificial intelligence that refer to nonexistent cases as well as to nonexistent quotations.”
US District Court, Eastern District of Texas (Beaumont Division), p. 1
“Monk explained that he used a generative artificial intelligence (“A.I.”) tool to produce the Response and failed to verify the content.”
US District Court, Eastern District of Texas (Beaumont Division), p. 2
“Here, Monk submitted the Response without reading the cases cited, or even confirming the existence or validity of the cases included therein.”
US District Court, Eastern District of Texas (Beaumont Division), p. 5
“Monk is ordered to pay a $2,000 penalty into the registry of the court;”
US District Court, Eastern District of Texas (Beaumont Division), p. 6

Timeline

  1. Goodyear moved for summary judgment.
  2. Plaintiff filed the response containing nonexistent cases and quotations.
  3. Plaintiff filed a sur-reply that did not address Goodyear's authenticity challenge.
  4. Court ordered counsel to show cause under Rule 11 and local rules.
  5. Counsel sought leave to amend and remove the false material.
  6. Court held the show-cause hearing.
  7. Court imposed a $2,000 penalty, AI CLE and client-notice requirement.

Why this case matters

Gauthier is one of the tracker records naming Claude rather than ChatGPT. It also shows that an AI check by another product did not cure the Rule 11 problem: Monk said Lexis AI failed to flag the false material, but the court focused on his failure to read and verify the cases himself. Unlike Mata, the court allowed amendment and imposed a modest court penalty plus a one-hour AI CLE course, while making the verification duty explicit under a local rule on computer-generated content.

Practice note

After using a drafting tool, counsel must open each cited authority and read the quoted passage before filing. A second AI tool that says nothing is not verification. If opposing counsel identifies nonexistent authorities, the lawyer should address the issue in the next filing and seek correction immediately, not wait for a show-cause order.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281 (E.D. Tex.)”, safelegalai.com/tracker/gauthier-v-goodyear (accessed 2026-09-16). Data: CC BY 4.0.

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