Disability Rights Mississippi v. Palmer Home for Children
The case
Disability Rights Mississippi v. Palmer Home for Children, N.D. Miss., No. 1:24-cv-00099-SA-DAS. Sanctions order filed December 19, 2025 by Senior Judge Sharion Aycock against attorney Greta Kemp Martin. Primary order: https://cases.justia.com/federal/district-courts/mississippi/msndce/1:2024cv00099/49389/89/0.pdf ; reported at: https://news.bloomberglaw.com/litigation/mississippi-lawyer-to-pay-20-000-take-cle-for-ai-missteps
What happened
Attorney Greta Kemp Martin submitted legal memoranda containing fabricated case citations and nonexistent quotations. Judge Aycock said she was "highly suspicious" that Martin used an AI tool to generate the made-up authorities.
The rule and the sanction
Violation of the duty of reasonable inquiry (Rule 11) and candor obligations: $20,883.10 in fees and costs, plus 3 hours of CLE on AI, against attorney Greta Kemp Martin.
How it could have been avoided
Verify that every cited authority exists and that every quotation is genuine before filing; the same checks that would have caught the fabrication here. Proactive AI-ethics education costs far less than a $20,000 sanction.