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 124, 9 June 2026 · source · PDF · 44 pages
Docket text. Transcript of Proceedings, Show Cause Hearing held on 1/20/2026 before Judge Sharion Aycock. Court Reporter/Transcriber Phyllis K. McLarty, Telephone number 662-369-1017. NOTICE RE REDACTION OF TRANSCRIPTS: The parties have seven (7) days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The Policy is located on our website at www.msnd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER.. Redaction Request due 6/30/2026. Redacted Transcript Deadline set for 7/10/2026. Release of Transcript Restriction set for 9/8/2026. (pkm)
Wilson, and, Ms. Ridgeway, you both acknowledge and agree that AI was used in preparation of various proceedings that you presented in pleadings that you presented to this Court and that those turned out -- and we're going to go through them individually -- to be either, one, falsified citations and/or hallucinated cases? Now, who am I speaking to between the two of you?
Each of you did. And it's my belief that you have essentially admitted that you used AI cases, hallucinated cases, false representations of what those cases stood for. Is that correct?
City of Grenada. I believe these to be hallucinated cases. And so if you were able to produce two copies -- or produce a copy of that case, I'd be most interested in seeing it.
THE COURT: Thank you. I'm going to start -- because I want the record to be Case: 1:24-cv-00218-SA-RP Doc #: 124 Filed: 06/09/26 7 of 44 PageID #: 678 complete, I'm going to start by, first of all, acknowledging the numerous hours that have been expended in this case trying to track down what is falsified and hallucinated. And these law clerks to my right have spent a great deal of wasted time in trying to find these cases.
City of Grenada. So that -- is that a fair summation of the four cases that you cited that have -- either, one, stand for false premises of law or hallucinated cases? MS.
And you're saying that -- I'm sorry. Just to be clear, you're not saying that the case was hallucinated. You're saying the -- the -- THE COURT: You misstated the proposition of the case.
What -- I apologize to the Court. What case are you -- what case -- so this is not a hallucinated case. This is a -- this is a premise from that case?
This is a -- this is a premise from that case? THE COURT: This is you quoting material that does not exist in the case. MS.
Docket entry 123, 8 June 2026 · source · PDF · 23 pages
Docket text. SANCTIONS ORDER. Attorneys Kathryn Young Williams and Kathleen M. Wilson's PHV admission is REVOKED; Attorneys Mark C. McClinton and Shauncey Hunter Ridgeway are DISQUALIFIED from further participation in this case. Motions for Leave to File 112, 113 terminated as moot. Signed by Senior Judge Sharion Aycock on 6/8/2026. (jtm)
Upon reviewing the briefs submitted in support of the parties’ respective positions with regard to the two Mo tions [98, 103], the Court was unable to locate certain legal authorities cited within them. Speci fically, the Court determined that the following filings contained hallucinatory citations, which the Court also lists: 1) Defendant City of Aberdeen’s Memora ndum of Law in S upport of its Motion for Summary Judgment [99] citing Miller v. City of Greenville, 243 So.
See [112, 113]. Ultimately, through their respective Motions for Leave [112, 113], the attorneys admitted that the hallucinatory citati ons cited by them, and identified by the Court, resulted from unverified AI use. The Court held a show cause hearing on January 20, 2026 and all attorneys of record were in attendance.
They explained that they we re unaware of their respective co-counsel’s use of AI in this case. All attorneys involved first be came aware that hallucinated cases were cited in their respective filings upon receipt of the Court’s Show Cause Order [110] on December 10, 2025. At the hearing, attorneys for both sides represented to the Court that their respective clients were made aware of this impending issue.
Sols., Inc. , 168 F.4th 231, 240 (5th Cir. 2026) (holding that courts “have the inherent power to impose sanctions for abuse of the judicial process” a nd that “[s]ubmitting a brief riddled with fabricated [authority] is such an abuse.”). “While sanctions under this power do not require a violation of a court order (as would a sanction based on civil cont empt), they ordinarily require a specific finding of bad faith on the part of the party to be sanctioned.” Massachusetts Mut.
2d 27 (1991)). Case: 1:24-cv-00218-SA-RP Doc #: 123 Filed: 06/08/26 5 of 23 PageID #: 653 6 Analysis and Discussion This Court is yet again “burden[ed] [with] a ddressing AI hallucinations in court filings.” Fletcher, 168 F.4th at 234.1 It has previously acknowledged that “AI is a powerful tool, that when used prudently , provides immense benefits.” Billups v. Louisvi lle Mun.
By the same token, Wilson admitted to using gene rative AI to draft her respecti ve filing without verifying the legal authority incorporated into the generate d draft. Their practice of blindly relying on technology resulted in the hallucinatory citations contained in their respective filings. “To state ‘the obvious, an attorney who submits fake cases clearly has not read those nonexistent cases, which is a violation of Ru le 11 of the Federal Rules of Civil Procedure.’” Billups , 2025 WL 3691871 at *5 (quoting Willis v.
This Court has previously acknowledged that district courts “throughout the country have held that citing fictitious or fabricated legal authority in filings without verifying their accuracy is conduct tantamount to bad faith.” Disability Rts.
Mississippi, 2025 WL 3691876 at *12 (collecting cases). address the relevancy of that argument to the issu e at hand when analyzing Willilams’ specific conduct below but, for now, notes that she changed her position at the hearing and did not dispute her violation. Case: 1:24-cv-00218-SA-RP Doc #: 123 Filed: 06/08/26 7 of 23 PageID #: 655 8 In line with those decisions, the Fifth Circuit has held that the submission of briefs containing fabricated authority is an abuse of th e judicial process warranting sanctions under the inherent powers of courts. See Fletcher, 168 F.4th at 240.
Docket entry 112, 24 December 2025 · source · PDF · 3 pages
Docket text. MOTION for Leave to File Corrected Pleadings in Response to Show Cause Order (Docs. 110, 111) by Tom Withers, III. (Attachments: # 1 Exhibit 1 - Citation Review Chart, # 2 Exhibit 2 - Corrected Doc. 65, # 3 Exhibit 3 - Corrected Doc. 72, # 4 Exhibit 4 - Corrected Doc. 81, # 5 Exhibit 5 - Corrected Doc. 96, # 6 Exhibit 6 - Corrected Doc. 102, # 7 Exhibit 7- Corrected Doc. 105, # 8 Exhibit 8 - Corrected Doc. 108, # 9 Exhibit 9 - Corrected Doc. 108-1) (Ridgeway, Shauncey)
NO.: 1:24-cv-218-SA-RP CITY OF ABERDEEN Defendant PLAINTIFF’S MOTION FOR LEAVE TO FILE CORRECTED MEMORANDUM RESPONSE COMES NOW, Plaintiff Tom Withers, III, by and through undersigned counsel, pursuant to Local Uniform Civil Rule 7(b) and moves for leave to file corrected memoran da responses stating: 1. Upon review, and in accordance with this Honorable Court’s Show Cause Order (ECF 110), the undersigned counsel identified two hallucinated citations, resulting from unverified AI-generated research. The undersigned notes that one of the two hallucinated citations is in ECF 105 also appears in ECF 108-1.