Docket entry 28, 23 July 2025 · source · PDF · 7 pages
Docket text. ORDER The Court SANCTIONS Edward L. Pina as follows: 1. A monetary sanction of $2,500, to be paid into the Court registry within fourteen days of this Order. 2. Completion of a minimum of three hours of Continuing Legal Education in ethics or l egal technology, including at least one hour on the use of generative AI in the legal context, within ninety days of this Order, with proof of compliance filed on the docket. 3. Service of a copy of this Order on Plaintiff Karina Elizondo and filing of a certificate of service within fourteen days of this Order. (Signed by Judge Marina Garcia Marmolejo) Parties notified. (ges5)
5:25-cv-50 CITY OF LAREDO ORDER Before the Court is the question of whether to impose sanctions on Plaintiff’s counsel, Edward L. Piña, for filing a response to Defendant’s motion to dismiss that contained multiple fictitious or materially inaccurate case citations (Dkt. No.
1 After reviewing the response, the Court concludes that Mr. Piña violated Rule 11 of the Federal Rules of Civil Procedure by submitting a filing with fabricated citations and misstatements of law that were not properly reviewed for accuracy. As such, the Court will impose sanctions.
18). Up on review, the Court identified multiple citations in Plaintiff’s response that appear ed fictitious or materially inaccurate. The 1 As the Court afforded Mr.
DISCUSSION The Court finds that Mr. Piña’s filing of a brief containing fabricated or materially inaccurate case citations, which he acknowledges stemmed from the use of generative AI, constitutes a Rule 11 violation. “The Response presents a false statement of law to the Case 5:25-cv-00050 Document 28 Filed on 07/23/25 in TXSD Page 4 of 7 5 court, and it appears that [Mr.
Given that the Laredo Division is one of the busiest court dockets in the nation, there are scant resources to spare ferreting out erroneous AI citations in the first place, let alone surveying the burgeoning caselaw on this subject. The seriousness of filing fictitious case citations—and the corresponding waste of judicial and party resources—warrants a penalty sufficient to deter future violations like Mr. Piña’s, which courts have unfortunately “seen a rash of” in recent years.
28, 2025) (citations omitted); see also Benjamin, 2025 WL 1195925, at *1 (collecting cases). The Court also observes that Defendant, the City of Laredo, could have flagged these fictitious citations in a re ply brief or supplemental filing. See Gauthier, 2024 WL 4882651, at *1 (opposing party flagged AI misuse in its reply brief); Ferris, 2025 WL 1122235, at *1 (opposing party alerted the court to hallucinated cases).