Incident Tracker / United States (federal)
Wayne K. Smith, Sr. v. Polk County, et al.
On 2026-06-03, in Wayne K. Smith, Sr. v. Polk County, et al, the Western District of North Carolina ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order. Counsel filed an opening brief using quotations that did not appear in the cited source.
- Court
- United States District Court for the Western District of North Carolina
- Date
- 2026-06-03
- Who used the AI
- Lawyer
- AI tool
- GAI
- Conduct
- Counsel filed an opening brief using quotations that did not appear in the cited source.
- Outcome
- Pending
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-07
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
- James v. Conley, No. 1:23-cv-24467 (S.D. Fla.)2026-08-27 · US District Court for the Southern District of Florida (Magistrate Judge Elfenbein, report and recommendation) · PendingIn the US District Court for the Southern District of Florida, a magistrate judge found that plaintiff's Fifth Amended Complaint pleaded nonexistent police-training publications that counsel conceded were AI hallucinati…
- Booker v. The Kroger Co., No. 1:26-cv-02006-SDG (N.D. Ga.)2026-08-28 · US District Court for the Northern District of Georgia, Atlanta Division · FineThe US District Court for the Northern District of Georgia fined employment plaintiff's lawyer Christopher Johnson USD 8,000, payable to the court's sanctions fund, for citing four nonexistent or misrepresented authorit…
- Adams v. Matrix Providers, No. 1:23-cv-01996 (D. Colo.)2026-08-27 · US District Court for the District of Colorado · FineThe US District Court for the District of Colorado fined counsel Ms Pearson USD 1,000 after her brief cited a nonexistent case and attributed a quotation to Justice Scalia from an opinion dated 2020, four years after hi…
- Williams v. Dallas-Fort Worth International Airport Board, No. 4:26-cv-00433-P (N.D. Tex.)2026-08-27 · US District Court, Northern District of Texas · WarningIn the Northern District of Texas, plaintiffs' counsel cited nonexistent and materially inapposite cases while trying to defeat qualified immunity. Judge Pittman called the effort borderline sanctionable, warned that ge…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Wayne K. Smith, Sr. v. Polk County, et al.”, safelegalai.com/tracker/wayne-k-smith-sr-v-polk-county-et-al (accessed 2026-09-08). Data: CC BY 4.0.