Massachusetts · federal district court · 2025

Vita Law Offices, P.C. v. Lockridge Grindal Nauen P.L.L.P.

District Court, D. Massachusetts, 14 July 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · D. Mass.

  1. Court. District Court, D. MassachusettsCOURT
  2. Level. federal district courtLEVEL
  3. Date. 14 July 2025DATED
  4. Docket. No. 1:25-cv-11518DOCKET
  5. Judge. Brian E. MurphyJUDGE
  6. Documents. one document, 6 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 26, 14 July 2025 · source · PDF · 9 pages

Docket text. Response to Order to Show Cause

As detailed below, Plaintiff has conducted a thorough review of all briefs submitted in this action, identified all instances of inaccurate quotations, and provides explanation for how they occurred. Plaintiff respectfully requests that the Court decline to issue sanctions, as these errors do not involve fabricated cases or intentional misconduct, distinguish from cases imposing sanctions for AI-generated "hallucinations," and Plaintiff has taken immediate remedial steps to prevent recurrence. This response is supported by the attached Declaration of Christopher M.

COUNSEL IS DEEPLY EMBARRASED AND REGRETFUL AND PRAYS THAT THE COURT SHOW LENIENCY IN LIGHT OF THE UNINTENTIONAL NATURE OF THESE ERRORS. Counsel prays respectfully that this Court would not issue sanctions, as the inaccuracies stem from an unintentional editing error during grammar refinement, not from bad faith, fabricated cases, or AI "hallucinations" (i.e., generating nonexistent authorities). Federal Rule of Civil Procedure 11(b) requires good-faith inquiry and non-frivolous arguments, but courts exercise discretion in imposing sanctions, considering intent, remedial actions, and the nature of the error.

B. Distinguished from AI "Hallucination" Cases Warranting Sanctions Courts imposing sanctions for AI misuse typically involve "hallucinations" which generate fake cases or holdings – often during substantive research, not editing. In Mata v.

In Mata v. Avianca, attorneys used ChatGPT for legal research, submitting six (6) nonexistent cases, leading to a $5,000 fine for bad faith. Mata v.

(emphasis added). These cases underscore the severity of citing nonexistent cases, a contrast to the present situation where all 226 citations are real, and the errors limited to altered wording in thirteen (13) quotes or partial-quotes from valid authorities, namely Carden v. Arkoma Associates, 494 U.S.

The cases where sanctions were imposed involve 8 deliberate or reckless reliance on AI for substantive content, unlike Counsel’s limited use of Copilot for grammar edits. In counsel’s review of instances where sanctions, fines or costs were imposed, it appears that all of them involved “hallucinated” case cites (cases that do not exist and are used to purport and support an argument before the Court). In this instance, Counsel’s use of the quote, while erroneous, was cited to an actual case, and a case that in fact did support the arguments being raised to this Court.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.

More from District Court, D. Massachusetts, from Massachusetts, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

Show me on one of my files →

This case is about a cite nobody opened. See a cite checked against the record before it renders, on your own file.

Show me on my files