Jodell Dodge v. FirstService Residential Arizona LLC
The case
Jodell Dodge v. FirstService Residential Arizona LLC, No. CV-24-01550-PHX-SMM (D. Ariz.), order signed December 8, 2025 and filed December 17, 2025. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-118-dodge-v-firstservice.pdf`. Source URL: https://www.damiencharlotin.com/documents/1195/Dodge_v._FirstService_USA_17_November_2025.pdf
What happened
Attorney Matthew V. Moosbrugger used "Federally Lawyer," an add-on to enterprise ChatGPT, to prepare a filing. He did not independently verify the citations; instead he asked ChatGPT whether the authorities were real and accurate. The filing had nine citation deficiencies, including the nonexistent case Gestalt v. City of Gloucester.
The rule and the sanction
The court found the conduct violated the duties of candor and reasonable inquiry. It deemed public exposure of the misconduct a sufficient deterrent and ordered no further sanctions, but it expressly directed the clerk to provide copies of the order to the State Bar of Arizona Disciplinary Committee.
How it could have been avoided
(a) Never ask an AI tool to verify its own output; verification must come from an independent primary source. (b) Read each cited case to confirm it exists and supports the proposition before filing.