Docket entry 28, 22 May 2026 · source · PDF · 6 pages
Docket text. ORDER. Signed by Chief District Judge Halil S. Ozerden on May 22, 2026. (cs)
1:25-cv-268-HSO-BWR JOHN S. RISCASSI, in his official capacity as the Chief Operating Officer of the Armed Forces Retirement Home DEFENDANT ORDER On May 1, 2026, the Court ordered Counsel for Plaintiff, Aaron Randall Rice, to show cause why he should not be sanctioned for failure to comply with Federal Rule of Civil Procedure 11 by signing and filing a Response [20] in Opposition to Defendant’s Motion [18] for Summary Judgment that contained a citation to a fictitious case and quotations that do not appear in a real case. See Ord.
I. BACKGROUND This case stems from what has become an all-too-familiar occurrence in court filings: the citation to fictitious legal authority. On February 5, 2026, attorney Aaron Randall Rice filed a Response [20] in Opposition to Defendant’s Motion [18] for Summary Judgment.
[20] at 4. That case does not exist. The Response [20] also contained two quotations to Minnesota Voters Alliance v.
Although Mr. Rice is “not certain it came from the AI preview, simply because [he is] skeptical of AI responses and do[es] not use interactive AI tools for legal research,” he recognizes that because “the citation refers to a nonexistent opinion . . . it may have appeared there, particularly since [he] planned to verify online citations with Fastcase regardless of their specific source.” Id. Regrettably, while “rushing to meet the deadline” to submit his brief, Mr.
But to Mr. Rice’s credit, he appears to have taken full responsibility for this mistake and has acknowledged that citing fictitious cases poses a “danger . . . to the proper administration of justice.” Id. at 5. Turning to errors identified in Mansky, they appear to stem from a lack of attention to detail.
2024). And courts in the Fifth Circuit have recognized that attorneys shirk their Rule 11 obligations when they fail to verify the information contained in their briefs, like citing fictitious cases. See, e.g., Ferris v.
5 Although Mr. Rice is “not certain [the fictitious case] came from the AI preview,” on his web searches, Resp. [27] at 4, the case does not exist, and in the Court’s view it is hard to see what else would have generated the fake case.
And in any event, when Mr. Rice filed his brief containing a non-existent case—regardless of its source—he violated Rule 11 . As for the misquotations to Mansky, the Court is satisfied that those errors were the result of a lack of attention to detail.