MEDICAL BUYERS GROUP LLC v. PENCE

Docket entry 66, 20 January 2026 · source · PDF · 10 pages

Docket text. ORDER granting in part 54 Motion for Attorney Fees and granting in part 55 Motion for Attorney Fees. Ordered by US DISTRICT JUDGE TILMAN E SELF, III on 1/20/2026 (vs)

41]. In their Replies, Defendants pointed out that some of the cases Integrity cited in its Responses did not exist. See, e.g., [Doc.

2]. Defendants also mentioned sanctions against counsel for Integrity for citing to hallucinated cases, with 2 P4 and Lisa explicitly requesting that the Court impose sanctions. [Doc.

[Id.]. Counsel for Integrity filed a Response in which he admitted to using hallucinated cases and detailed the steps he had already taken to remedy the mistake. [Doc.

The Court also recognizes that this was not intentional. However, courts have found that citing to hallucinated cases constitutes bad faith, even when unintentional. See United States v.

The Court also considered the “overall sense of the suit” and its goal in effectuating justice in the form of compensation rather than punishment. Specifically, the Court considered that this is a case with multiple Defendants who should be compensated for wasting time researching hallucinated cases. After all, it should be time consuming to acquire enough confidence in the non- existence of something to accuse the other party of fabricating it.

To require counsel for Integrity to pay for the Court’s order also errs toward punishment. With those considerations in mind, the Court exercises its considerable discretion under its inherent powers and ORDERS counsel for Integrity to pay $10,000 in attorney’s fees as sanctions for citing nonexistent cases hallucinated by AI. Counsel will pay $5000 to counsel for P4 and Lisa, and $5000 to counsel for Candice within 60 days.

Docket entry 52, 18 November 2025 · source · PDF · 4 pages

Docket text. ORDER: The Court publicly admonishes Mr. Gordon for submitting hallucinated and false case citations to the Court without properly authenticating them. Within 14 days, Defendants may submit motions to recoup their reasonable attorneys fees for having to research and respond to non-existent case citations and holdings. Mr. Gordon shall then have 14 days to respond. There will be no replies.Other than attorneys fees, there will be no other monetary sanctions in this case. Failure to abide by these terms shall be punishable by contempt. Ordered by US DISTRICT JUDGE TILMAN E SELF, III on 11/18/2025. (vs)

Specifically, Mr. Gordon cited several cases that do not exist, and one case that does not support the proposition for which he cited it. See [Doc.

In his response to the Court’s Order to Show Cause, Mr. Gordon admitted to using Artificial Intelligence (“AI”) to draft the briefs and failing to catch the AI’s made-up citations. [Doc.

The Court concludes that Mr. Gordon clearly violated Rule 11(b)(2) by presenting pleadings to it containing citations to legal authority that either did not exist or did not support the proposition for which they were cited. With that said, the Court wishes to publicly acknowledge Mr.

4 • The Court publicly admonishes Mr. Gordon for submitting hallucinated and false case citations to the Court without properly authenticating them. • Within 14 days, Defendants may submit motions to recoup their reasonable attorney’s fees for having to research and respond to non- existent case citations and holdings. Mr.

Docket entry 43, 4 November 2025 · source · PDF · 6 pages

Docket text. Order to Show Cause

3:25-cv-00105-TES AMENDED ORDER TO SHOW CAUSE First – a little accountability from the Court. The Court issued an Order to Show Cause on October 31, 2025, regarding some allegedly hallucinated AI cites and improper citations. [Doc.

2]. In addition to legal arguments, Defendants also accuse their opposing counsel of using fabricated citations in its responses to Defendants’ motions to dismiss. [Doc.

Serious accusations to be sure. In light of the seriousness of the accusations, the Court has conducted independent searches for each allegedly fabricated citation, to no avail.1 The Court has also read Encompass, 775 F. Supp.

11(b)(2) (emphasis added). “The issue of ‘hallucinated cases created by generative artificial intelligence (AI) tools such as ChatGPT and Google Bard’ has been ‘widely discussed by courts grappling with fictitious legal citations and reported by national news outlets.’” Boston, et al. v. Williams, et al., No.

62. “Put bluntly[,] . . . citing nonexistent case law or misrepresenting the holdings of a case is making a false statement to a court.” United States v. McGee, No.

3.3 (2025). Said counsel is ORDERED to append to his filings copies of each allegedly fabricated legal authority;2 if he cannot provide such copies, counsel is further ORDERED to submit sworn declarations that provide a thorough explanation for how the motion and allegedly fabricated cases and holdings were generated, and his role in drafting or supervising the motion. But Plaintiff’s counsel aren’t alone in potential ethics violations.

Looking to the other side, counsel for Defendants Lisa Pence and P4 Biologix failed to cite Integrity’s operative response to their motion to dismiss [Doc. 37] when they accused Plaintiff’s counsel of using hallucinated citations. See, e.g., [Doc.

19]. However, for the sake of full disclosure and candor, the Court requires Integrity’s counsel to append all allegedly fabricated legal authority, including the “Bliss” cite. 6 the court understands counsel’s desire to point out Integrity’s allegedly hallucinated cases, counsel could have done so through Integrity’s operative response.