Incident Tracker / United States (federal)
In re BFI Waste Systems of Tennessee (City of Murfreesboro v. BFI), No. 3:22-cv-00605 (M.D. Tenn.)
·US District Court for the Middle District of Tennessee, Nashville Division·US-FEDSanctions
The US District Court for the Middle District of Tennessee publicly reprimanded attorney Louis Ringger III and ordered him to pay USD 1,500 to the Clerk after a brief in landfill litigation quoted cases that did not say what was claimed. The court kept the sanction low because counsel accepted responsibility and had already imposed firm-wide verification measures.
- Court
- US District Court for the Middle District of Tennessee, Nashville Division
- Date
- 2026-08-06
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- A plaintiff's filing (Doc. 293) in long-running landfill litigation contained hallucinated quotations and misleading or nonexistent citations; the show-cause order was Doc. 321. Attorney Louis W. Ringger III responded on behalf of all lawyers involved, took responsibility as the document's sole drafter, attributed the errors to unchecked AI-powered research and adopted firm-wide remedial measures.
- Outcome
- Sanctions
- Penalty
- US$1,500
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
What was fabricated or misused
- Doc. No. 293; hallucinated quotations and misleading citations, with the authorities not enumerated in the order
- quotations that did not exist and citations suggesting unsupported arguments had support
What the court said
“Combined with the voluntary remedial measures that Ringger already has taken, a small monetary sanction will suffice to emphasize that wasting the Court's time and limited resources chasing false legal authority must not happen again.”
“The supervisory attorney, however, always bore ultimate responsibility for the accuracy of the final product.”
“The novel danger with artificial intelligence is how much easier a Rule 11 violation becomes when using it.”
“Ringger fell short, with quotations that did not exist and with legal citations that gave the impression that an argument in his favor had support when it did not.”
Timeline
- Court ordered plaintiff's attorneys to show cause over Doc. No. 293.
- Court filed its sanctions order after considering Ringger's response.
- Court publicly reprimanded Ringger and assessed a $1,500 sanction.
- Court allowed filing of the proposed supplemental corrected response.
Why this case matters
BFI is a mitigation contrast to Johnson v Dunn and Chapman v City of Priceville. The Middle District of Tennessee still imposed Rule 11 sanctions for false authority, but the court kept the amount at USD 1,500 because Ringger accepted responsibility, apologized and had already taken remedial steps. The order also names the supervising-lawyer problem directly: AI research is allowed, but the signer remains responsible for the final product. That makes the record useful for separating prompt correction and firm-level controls from cases where lawyers filed more false material after notice.
Practice note
Supervising counsel should require a final citation audit before any AI-assisted filing is submitted. The audit should confirm each quotation appears in the cited source and each citation supports the proposition. If an error is found, file a corrected document and explain the remedial steps without waiting for the court to do the checking.
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, “In re BFI Waste Systems of Tennessee (City of Murfreesboro v. BFI), No. 3:22-cv-00605 (M.D. Tenn.)”, safelegalai.com/tracker/in-re-bfi-waste-systems (accessed 2026-10-07). Data: CC BY 4.0.