US | United States District Court for the Eastern District of Texas
Docket: 1:23-cv-281 • first instance
2024-11-25
Gauthier v. Goodyear Tire & Rubber Co. — memorandum and order
Claude no human verificationfake case citationfake quotationfailure to correct after notice
I. Executive Summary
The court considered whether plaintiff’s counsel should be sanctioned for filing a summary-judgment response containing AI-generated citations to non-existent cases and quotations that could not be found in cited authorities.
Counsel acknowledged using the generative AI tool Claude and failing to verify the content. The court imposed sanctions to deter similar submissions.
II. Conduct Analysis
Counsel used Claude to draft a response brief and included hallucinated case citations and unsupported quotations without independently verifying that the authorities existed or contained the quoted language, even after opposing counsel flagged the problem.
III. Legal Foundations
Fed. R. Civ. P. 11(b)(2)
E.D. Tex. Local Rule AT-3(b)
E.D. Tex. Local Rule AT-3(m)
IV. Key Facts
1) A response opposing summary judgment cited two non-existent cases and included quotations that could not be located in the cited authorities.
2) Counsel admitted he used Claude to generate the response and failed to verify the citations and quotations.
3) After a show-cause order and hearing, the court found the conduct warranted deterrent sanctions.
V. Consequences & Sanction
1) The court imposed a monetary penalty payable to the court registry.
2) The court required counsel to complete AI-focused continuing legal education and to notify the client.