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Incident Tracker / United States (federal)

Williams v. Dallas-Fort Worth International Airport Board, No. 4:26-cv-00433-P (N.D. Tex.)

·US District Court, Northern District of Texas·US-FEDWarning

In 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 generative-AI misrepresentations of law may trigger Rule 11 sanctions, and dismissed the civil-rights claims against the airport-board defendants.

Court
US District Court, Northern District of Texas
Date
2026-08-27
Who used the AI
Lawyer
AI tool
Not identified in the record
Conduct
Plaintiffs' counsel relied on nonexistent and out-of-circuit cases while trying to establish clearly established law in a civil-rights action. The court called the presentation borderline sanctionable, warned that generative-AI misrepresentations may trigger Rule 11 sanctions, and dismissed the claims on qualified-immunity grounds.
Outcome
Warning
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997) — either nonexistent or mistakenly out-of-circuit and inapposite; the court said plaintiffs presumably meant Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008)
  • Yates v. Terry, 817 F.3d 877 (4th Cir. 2016) — out-of-circuit and materially dissimilar
  • Dawkins v. Fields 354 F.3d 392 (5th Cir. 2003) — the court could not find a case clearly establishing the point
  • Tennessee v. Garner, 471 U.S. 1 (1985) — misused to argue non-deadly force against a compliant, non-threatening person is unreasonable
  • Graham v. Connor, 490 U.S. 386 (1989) — did not clearly establish law for a single taser discharge against a non-compliant adult

What the court said

“This cannot be undertaken at too broad a level of generality, id., and it certainly cannot be established by citation to nonexistent cases.”
US District Court, Northern District of Texas, p. 5
“Here, Plaintiffs make a borderline sanctionable attempt to identify “clearly established” law from five cases.”
US District Court, Northern District of Texas, p. 5
“The Court cautions that use of generative artificial intelligence that results in repeated misrepresentations of law may qualify for sanctions under Fed. R. Civ. P. 11(b)–(c)”
US District Court, Northern District of Texas, p. 5 n.2
“The Court has little patience for such “lazy lawyering.””
US District Court, Northern District of Texas, p. 6

Timeline

  1. Airport incident involving the Williams plaintiffs occurred at DFW.
  2. Plaintiffs filed the civil-rights suit.
  3. Defendants filed the motion to dismiss addressed by the order.
  4. Court dismissed the section 1983 claims and warned about AI misrepresentations.

Why this case matters

Williams adds a qualified-immunity setting in which weak citation practice directly affected the clearly established law inquiry. Unlike Booker, the court issued a warning rather than a fine, but it linked hallucinated authority to Rule 11 because the plaintiff's burden required a close match to binding precedent. The record also shows a separate risk from AI research: even real out-of-circuit cases, or real Supreme Court cases stated at too high a level, cannot satisfy the Fifth Circuit standard.

Practice note

When opposing qualified immunity, build a table before filing: jurisdiction, facts, force used, procedural posture and holding for each case. Verify the reporter citation and court. Remove out-of-circuit cases unless they are used only for persuasive background, and do not cite broad Supreme Court excessive-force language as if it clearly establishes the precise conduct.

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, “Williams v. Dallas-Fort Worth International Airport Board, No. 4:26-cv-00433-P (N.D. Tex.)”, safelegalai.com/tracker/williams-v-dfw-airport-board (accessed 2026-10-07). Data: CC BY 4.0.

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