In re: Loletha Hale, Esq. (Boston v. Williams)

Selena Boston, et al. v. Micah Sierra Katt Williams, et al., No. 1:23-cv-00752-WMR, N.D. Ga., ancillary Rule 11 order (Document 70) filed October 28, 2025, sanctioning plaintiffs' counsel Loletha Hale. Copy of primary document: `files/sources/D-101-boston-v-williams.pdf`.

Hale filed a summary judgment response brief in which an overwhelming majority of the cited cases either did not exist, did not support the cited proposition, or misquoted the authority. The court found the brief was generated at least in part using AI. Hale told the court she had been distracted, had asked her daughter (who is not an attorney or paralegal) to draft the brief, and had failed to review it before filing. Her amended brief repeated at least one of the same citation errors.

The court found a violation of Federal Rule of Civil Procedure 11(b)(2) and imposed non-monetary sanctions: Hale must notify all of her existing clients in federal cases filed in the Northern District of Georgia of the court's findings, and must file a notice to the district court, with a copy of the order, in all pending and future cases filed in the Northern District of Georgia in which she appears as counsel, for five years. No monetary sanction was imposed; failure to comply is punishable by contempt. By follow-on order (Doc. 77, Dec. 5, 2025, denying reconsideration), the record shows the court had transmitted the October 28 order to the State Bar of Georgia, and a State Bar complaint against Hale followed.

Never delegate drafting to an unqualified person and file the result unread; the signing attorney owns every citation. Run every cited authority through a verification check, and confirm that an "amended" filing actually fixes the errors. Treat AI assistance as a trigger for extra verification, not less.