Docket entry 42, 26 January 2026 · source · PDF · 21 pages
Docket text. MEMORANDUM AND OPINION. SIGNED BY DISTRICT JUDGE MARK A. KEARNEY ON 1/26/26. 1/26/26 ENTERED & E-MAILED.(fdc) (Entered: 01/26/2026)
He simply signed his name. The paper he signed along with the New York attorney contained at least eight false case citation hallucinations generated by artificial intelligence. Our talented lawyers in Chamb ers caught these hallucinations and we directed counsel to show cause as to why we should not impose sanctions.
Lifetime Well opposed the Motion to dismiss on November 18, 2025.18 It did not use false citations but flagged one quotation presented by IBSpot.com which did not exist in the cited opinion.19 We granted IBSpot.com leave to confirm the sources of its citation errors or show cause as to why we should not impose sanctions for filing a Motion with readily apparent false citations or quotations.20 Attorney Anderson responded to the show cause order on December 5, 2025 and Attorney Goldin responded on December 9, 2025.
Nor can lawyers avoid sanctions by directing a 8 subordinate to file a pleading that will violate Rule 11(b).”45 We may “sanction lawyers for what they should have known, not just what they knew.”46 We may sua sponte “order an attorney . . . to show cause why conduct specifically described in the order has not violated Rule 11(b) ” and must issue an order before imposing monetary sanctions.47 The purpose of sanctions is to “deter repetition of the conduct or comparable conduct by others similarly situated” rather than penaliz e an attorney.48 “A sanction may include ‘non[-]monetary directives’ or ‘an order to pay a penalty into court,’ among other things.”49 Rule 11’s amendments “provides […]
We are guided by reasoning from our colleagues across the country addressing mis use of generative artificial intelligence without oversight. These violations persist despite repeated 9 judicial warnings and extensive public discussion of the risks associated with unverified artificial intelligence-assisted legal research.53 Courts accordingly continue to find it appropriate to impose sanctions on attorneys who violated Rule 11 by submitting filings relying on unsupported or fictitious legal authority . Monetary sanctions ranging from $1,000 to $10,000 are routinely imposed in response to such conduct.
Judge Scott issued a $2,500 sanction and ordered mandatory Continuing Legal Education where an attorney used ChatGPT to cite artificial cases in two separate motions .56 Judge Crone imposed a $2,000 sanction and ordered Continuing Legal Education for submitting a brief “without reading the cases cited, or even confirming the existence or validity of the cases included therein ” and after opposing counsel “ specifically identified the nonexistent legal authorities, ” the attorney “took no action to verify his research .” 57 Magistrate Judge Wormuth issued a $3,000 sanction and required the attorney self -report to the state bar disciplinary boards where the “citation errors [were] caused by […]
Attorney Goldin similarly admits the Motion to dismiss “included citations to some cases that were real but did not stand for the proposition asserted and contained non-existent quotes” and the “mistakes involved the use of generative artificial intelligence.” 80 He “accepts responsibility for his signature on the filing and recognizes the Court’s justifiable concern. ”81 Attorney Goldin does not appear to dispute his conduct violated Rule 11.82 Both Attorney Anderson and Attorney Goldin violated Rule 11 by signing and filing briefing containing false citations without confirming the accuracy of the legal authority presented.
We first address Attorney Goldin’s emphasis on the Motion’s asserted non -frivolous substance and partial success.88 This framing misses the point. The presence of some meritorious arguments does not excuse the inclusion of others supported by inaccurate, misleading, or fictitious citations. The Supreme Court through Rule 11 asks whether an attorney conducted a reasonable inquiry before signing and filing each legal contention presented to us.
Nor does partial success relieve this Chambers of the burden of independently verifying and scrutinizing legal authority certified as accurate by Attorneys Anderson and Goldin . We were required to identify and 16 disregard numerous fabricated citations before reaching the merits of any argument. Rule 11 exists to ensure courts may rely on the accuracy of the legal authority presented to them, not to excuse errors because some arguments ultimately succeed.