Liza Gardner v. Sean Combs, et al.
Repeat offender (verified in the record)
The case
Liza Gardner v. Sean Combs, et al., No. 2:24-cv-07729-LMG-JRA (D.N.J.), order entered December 15, 2025. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-119-gardner-v-combs.pdf`. Source URL: https://www.damiencharlotin.com/documents/1179/Gardner_v._Combs_USA_15_December_2025.pdf
What happened
Attorney Tyrone A. Blackburn used AI and incorporated the nonexistent case United States v. Masha plus fabricated legal propositions into a filing. He failed to verify the citations even after opposing counsel flagged them, and he had previously been sanctioned for similar conduct in Jakes v. Youngblood.
The rule and the sanction
The court imposed a $6,000 monetary sanction and ordered Blackburn to self-report to and seek assistance from the New Jersey and New York attorney-licensing entities, file a compliance report, and serve and discuss the sanctions materials with his client.
How it could have been avoided
(a) Verify each citation against a primary source, especially after an opponent flags a fake one. (b) A prior sanctions order for AI misuse makes verification mandatory, not optional. (c) Self-reporting and compliance programs do not substitute for checking citations before filing.