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Gauthier v. Goodyear Tire & Rubber Co.

Court
E.D. Texas
Jurisdiction
USA
Decided
2024-11-25
AI tool
Claude
Outcome
Monetary fine + Mandatory AI-related CLE Course + Disclosure to Client
Monetary penalty
2000 USD

What was hallucinated

False Quotes: Case Law | Quoted material attributed to Morales v. SimuFlite could not be located in the opinion. || Fabricated: Case Law | Fabricated Fifth Circuit case 'Roca v. King’s Creek Plantation, LLC' cited; court found it does not exist. || Fabricated: Case Law | Fabricated Fifth Circuit case 'Beets v. Texas Instruments, Inc.' cited; court found it does not exist. || False Quotes: Case Law | Quoted material attributed to White v. FCI USA, Inc. could not be located in the opinion. || False Quotes: Case Law | Quoted material attributed to Burton v. Freescale Semiconductor, Inc. could not be located in the opinion. || False Quotes: Case Law | Quoted material attributed to Texas Dep't of Human Servs. v. Hinds could not be located in the opinion. || False Quotes: Case Law | Quoted material attributed to Physio GP, Inc. v. Naifeh could not be located in the opinion. || False Quotes: Case Law | Quoted material attributed to City of Midland v. O’Bryant could not be located in the opinion. || False Quotes: Case Law | Quoted material attributed to the fabricated Roca case also could not be located (case itself nonexistent).

Details

AI UseMonk admitted using the Claude AI tool to draft a summary judgment opposition without adequately verifying the case citations or quotations. He later claimed to have attempted post-hoc verification through Lexis AI but did not correct the errors until after a judicial show cause order.Hallucination DetailsCited two completely nonexistent cases. Also fabricated quotations attributed to real cases, including Morales v. SimuFlite, White v. FCI USA, Burton v. Freescale, among others. Several "quotes" did not appear anywhere in the cited opinions.Ruling/SanctionThe court imposed a $2,000 fine, ordered Monk to complete at least one hour of CLE on generative AI in legal practice, and mandated formal disclosure of the sanctions order to his client. It also permitted amendment of the defective filing but warned of the severity of the misconduct.Key Judicial ReasoningThe court emphasized that attorneys remain personally responsible for the verification of all filings under Rule 11, regardless of technology used. Use of AI does not dilute the duty of candor. Continued silence and failure to rectify errors after opposing counsel flagged them exacerbated the misconduct.

Sanction teardown · E.D. Texas, USA · 2024-11-25

Gauthier v. Goodyear Tire & Rubber Co.

What happened

In E.D. Texas, USA, a filing relied on Claude to help draft legal argument. The court identified the following problems with the citations in that filing:

  • False Quotes (Case Law)
    Quoted material attributed to Morales v. SimuFlite could not be located in the opinion.
  • Fabricated (Case Law)
    Fabricated Fifth Circuit case 'Roca v. King’s Creek Plantation, LLC' cited; court found it does not exist.
  • Fabricated (Case Law)
    Fabricated Fifth Circuit case 'Beets v. Texas Instruments, Inc.' cited; court found it does not exist.
  • False Quotes (Case Law)
    Quoted material attributed to White v. FCI USA, Inc. could not be located in the opinion.
  • False Quotes (Case Law)
    Quoted material attributed to Burton v. Freescale Semiconductor, Inc. could not be located in the opinion.
  • False Quotes (Case Law)
    Quoted material attributed to Texas Dep't of Human Servs. v. Hinds could not be located in the opinion.
  • False Quotes (Case Law)
    Quoted material attributed to Physio GP, Inc. v. Naifeh could not be located in the opinion.
  • False Quotes (Case Law)
    Quoted material attributed to City of Midland v. O’Bryant could not be located in the opinion.
  • False Quotes (Case Law)
    Quoted material attributed to the fabricated Roca case also could not be located (case itself nonexistent).

Which AI tool

Claude. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary fine + Mandatory AI-related CLE Course + Disclosure to Client (monetary penalty: 2000 USD.)

Additional detail

AI UseMonk admitted using the Claude AI tool to draft a summary judgment opposition without adequately verifying the case citations or quotations. He later claimed to have attempted post-hoc verification through Lexis AI but did not correct the errors until after a judicial show cause order.Hallucination DetailsCited two completely nonexistent cases. Also fabricated quotations attributed to real cases, including Morales v. SimuFlite, White v. FCI USA, Burton v. Freescale, among others. Several "quotes" did not appear anywhere in the cited opinions.Ruling/SanctionThe court imposed a $2,000 fine, ordered Monk to complete at least one hour of CLE on generative AI in legal practice, and mandated formal disclosure of the sanctions order to his client. It also permitted amendment of the defective filing but warned of the severity of the misconduct.Key Judicial ReasoningThe court emphasized that attorneys remain personally responsible for the verification of all filings under Rule 11, regardless of technology used. Use of AI does not dilute the duty of candor. Continued silence and failure to rectify errors after opposing counsel flagged them exacerbated the misconduct.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/238/Gauthier_v._Goodyear_US_DC_Eastern_Texas_November_25_2024.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/238/Gauthier_v._Goodyear_US_DC_Eastern_Texas_November_25_2024.pdf

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