Incident Tracker / United States (state)
Smith v. Farwell, No. 2282CV01197 (Mass. Super. Ct., Norfolk Cnty.)
·Massachusetts Superior Court, Norfolk County (Davis, J.)·US-STATESanctions
In the Massachusetts Superior Court for Norfolk County, Judge Brian A. Davis ordered plaintiff's counsel to pay $2,000 under Mass. R. Civ. P. 11 and 7 after an associate used an unidentified AI system to produce four fictitious case citations that counsel filed without checking. The court named no attorney and made no referral.
- Court
- Massachusetts Superior Court, Norfolk County (Davis, J.)
- Date
- 2024-02-12
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- Plaintiff's counsel filed four memoranda opposing motions to dismiss that relied on four wholly fictitious cases — Bartlett v. Gray, Estate of Berthiaume v. Pratt, Buckley v. Park Ward Motors and Korff v. Greater Lowell Mental Health Association. An associate had used an unidentified AI system; counsel reviewed the filings for style but never checked the citations.
- Outcome
- Sanctions
- Penalty
- US$2,000
- Regulatory outcome
- No separate regulatory disposition recorded
- 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, “Smith v. Farwell, No. 2282CV01197 (Mass. Super. Ct., Norfolk Cnty.)”, safelegalai.com/tracker/smith-v-farwell (accessed 2026-09-05). Data: CC BY 4.0.