Docket entry 37, 2 June 2026 · source · PDF · 15 pages
Docket text. ORDER ISSUING RULE 11 SANCTIONS TO PLAINTIFF FOR THE MISUSE OF ARTIFICIAL INTELLIGENCE IN COURT FILINGS. Signed by Chief Judge Sheryl H. Lipman on 6/2/2026. (shl)
16.) Amid the briefing of those motions, Defendants raised concerns that RLF was using generative artificial intelligence (“GAI”) in the drafting of its filings, identifying a host of issues tied to the alleged GAI use. Specifically, Defendants’ response to RLF’s Partial Motion to Dismiss asserts that Plaintiff relies on cases that do not stand for the propositions for which they are cited, and, even worse, RLF includes quotations from those cases that do not exist. (See ECF No.
(ECF No. 24 at PageID 316.) For instance, the Response to the Motion for Judgment on the Pleadings cites to numbered paragraphs from RLF’s complaint that do not exist and to facts that the complaint does not allege. (See ECF No.
(See ECF No. 20 at PageID 277 (citing to ¶¶ 69–70 of the complaint, which only contains forty-seven numbered paragraphs).) The response and its supplement also include citations to cases that do not exist, misrepresent the holdings from cases that do exist, and include quotations that were spun out of whole cloth. (See, e.g., ECF No.
For each of the cases Plaintiff lists in that filing, Plaintiff’s counsel shall do the following: (1) confirm whether the case exists and, if it does, describe the means by whic h its existence was verified; (2) confirm whether each case stands for the proposition Plaintiff cites; (3) confirm whether any language quoted actually comes from the cited case, or, if it does not, identify the case where it can be found if there is one; and (4) as to any case that does not exist, does not stand for the proposition for which it is cited, or does not contain the cited quotations, Plaintiff’s counsel shall identify what steps, if any, it had taken prior to citing to the cases to verify their […]
Stone & Hinds, P.C., 813 S.W.2d 400 (Tenn. 1991), from which Plaintiff includes a quote that does not exist. • White v. McBride, 937 S.W.2d 796 (Tenn.
McBride, 937 S.W.2d 796 (Tenn. 1996), from which Plaintiff also includes a quote that does not exist. • Hoover v. Langston Equip.
It did not confirm whether any language quoted actually came from the cited cases, or, if it did not, identify the case where it can be found if there was one. RLF did not—for cases that did not exist, did not stand for the proposition for which they were cited, or did not contain the cited quotation—identify what steps, if any, it had taken prior to citing to the cases to verify their existence. 4 4 RLF’s response includes an email from July 15, 2025, sent from Henry Reaves with the subject line “Mandatory Ethical AI Training & Reporting Protocols for All Staff.” (ECF No.
4 4 RLF’s response includes an email from July 15, 2025, sent from Henry Reaves with the subject line “Mandatory Ethical AI Training & Reporting Protocols for All Staff.” (ECF No. 31 at PageID 425.) That email appears to have been sent to two RLF employees with the directive 11 RLF also did not identify if there are any additional cases filed in any other matter currently before any court in the Western District of Tennessee in which RLF cited to non- existent cases or cited fictitious quotations. It did not provide a list of any such cases and a citation to the specific filings in each of those cases that contain any such materials.