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Incident Tracker / United States (federal)

Mid Central Operating Engineers Health and Welfare Fund v. HoosierVac LLC, No. 2:24-cv-00326-JPH-MJD (S.D. Ind.)

·US District Court, Southern District of Indiana (Terre Haute Division)·US-FEDSanctions

In the Southern District of Indiana, Magistrate Judge Mark J. Dinsmore recommended a $15,000 Rule 11 sanction against attorney Rafael Ramirez for three briefs citing non-existent AI-generated cases and referred him to the Chief Judge; on 28 May 2025 the district judge adopted the recommendation in part, reducing the sanction to $6,000.

Court
US District Court, Southern District of Indiana (Terre Haute Division)
Date
2025-05-28
Who used the AI
Lawyer
AI tool
Not identified in the record
Conduct
Defence counsel Rafael Ramirez filed three briefs (Dkts. 39, 52, 65) citing cases that do not exist, admitting at a show-cause hearing that he relied on generative AI tools without verifying the citations. Magistrate Judge Mark J. Dinsmore recommended a $15,000 Rule 11 sanction on 21 February 2025 and referred him to the Chief Judge; the district judge adopted the recommendation in part on 28 May 2025, imposing $6,000.
Outcome
Sanctions
Penalty
US$6,000
Regulatory outcome
Chief Judge, S.D. Ind. (Local Rule of Disciplinary Enforcement 2(a)); onward reference to the Indiana attorney disciplinary commission per Dkt. 103: Referred for consideration of further discipline; outcome of disciplinary reference not confirmed (2025-02-21)
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • In re Cook County Treasurer, 773 F.3d 834 (7th Cir. 2014) — cited in Dkt. 65; the magistrate judge was unable to locate it
  • Knoedler Manufactuers, Inc. v. Cox, 545 F.2d 1033, 1035 (7th Cir. 1976) — cited in Dkt. 39; the magistrate judge was unable to locate it
  • Brown v. Local 58, IBEW, 628 F.2d 441 (6th Cir. 1980) — cited in Dkt. 52; the magistrate judge was unable to locate it

What the court said

“filing a brief with a non-existent citation falls far short of an attorney's duty to the Court, his client, and opposing counsel.”
US District Court, Southern District of Indiana (Terre Haute Division), Dkt. 99 p. 2
“It is abundantly clear that Mr. Ramirez did not make the requisite reasonable inquiry into the law.”
US District Court, Southern District of Indiana (Terre Haute Division), Dkt. 99 p. 4
“the use of artificial intelligence must be accompanied by the application of actual intelligence in its execution.”
US District Court, Southern District of Indiana (Terre Haute Division), Dkt. 99 p. 6
“The Court concludes that a sanction of $6,000 "suffices to deter repetition of the conduct or comparable conduct by others similarly situated."”
US District Court, Southern District of Indiana (Terre Haute Division), Dkt. 121 p. 3

Timeline

  1. Ramirez filed the reconsideration brief citing In re Cook County Treasurer.
  2. The magistrate judge issued a Rule 11 show-cause order after finding more unlocated citations.
  3. At the hearing, Ramirez admitted relying on generative AI and not verifying the citations.
  4. The magistrate judge recommended a $15,000 sanction and referred the matter to the Chief Judge.
  5. The district judge adopted the recommendation in part and imposed a $6,000 sanction.

Why this case matters

Mid Central sits between small-fine hallucination cases and the later, harsher Johnson order. The magistrate judge recommended $15,000 because three separate briefs reached the court and opposing counsel, and the district judge still imposed $6,000 after accounting for Mr Ramirez's later AI education and reputational harm. Compared with Gauthier v Goodyear or Mortazavi v Booz Allen, the sanction reflects repeated filings rather than a single false citation. It also produced a local disciplinary referral under the Southern District of Indiana rules.

Practice note

Rule 11 requires the lawyer who signs or files the brief to make a reasonable legal inquiry. If AI supplies a case, verify existence, citation, pin cite and proposition in Westlaw, Lexis, CourtListener or the official court source before serving the brief. A later apology did not erase the violation because three filings had already used non-existent cases.

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, “Mid Central Operating Engineers Health and Welfare Fund v. HoosierVac LLC, No. 2:24-cv-00326-JPH-MJD (S.D. Ind.)”, safelegalai.com/tracker/mid-central-operating-engineers-v-hoosiervac (accessed 2026-10-07). Data: CC BY 4.0.

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