Hatfield v. Pirani

Hatfield v. Pirani, No. 5:22-cv-05110-TLB (W.D. Ark.), Opinion and Order (Document 451), filed December 3, 2025. Federal district court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-113-hatfield-v-pirani.pdf`.

Defendant Tony Pirani (and Pirani Law PA) filed motions in limine containing citations to nonexistent cases and quotations of nonexistent case law passages, which the court had already stricken as AI hallucinations, and failed to confer with opposing counsel on pretrial submissions as required by the scheduling order. Pirani attributed the failures to a severe medical illness in June 2024, but the court found the AI-generated filings postdated his return and his chronic missed deadlines predated the illness.

Rule 11(b)(2), Federal Rules of Civil Procedure. Sanctions: $1,000 fine payable to the Clerk of the Court (The fine is imposed on Mr. Pirani (ORDER p. 12); the decretal paragraph (p. 13) orders 'Defendants Tony Pirani and Pirani Law PA' to pay it.); Pirani may not enter any new appearances as counsel of record in the Western District of Arkansas until the fine is paid in full; for two years after the fine is paid, he must associate counsel on all W.D. Ark. appearances, with co-counsel equally responsible for any missed deadlines or misconduct; and the court forwarded the opinion and related materials to the Arkansas Judiciary's Office of Professional Conduct. (Self-reporting to the disciplinary office did not relieve the court's duty to refer.)

(a) Health problems do not excuse filing unverified AI-generated authority a year later; reduce caseload instead. (b) The court treated striking the filings as no real sanction because Pirani got a full and fair opportunity to object at trial anyway; deterrence requires more. (c) Self-reporting to a disciplinary authority does not substitute for the court's own referral.

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