Case D-130 · AI Sanctions Case Tracker

Woodward Harbor L.L.C. v. City of Mandeville

E.D. Louisiana, March 5, 2026

The case

Woodward Harbor L.L.C. v. City of Mandeville, E.D. Louisiana, No. 23-5824, Document 117, filed March 5, 2026. Copy of primary document: `files/sources/D-130-woodward-harbor-v-mandeville.pdf`. Source URL: https://www.damiencharlotin.com/documents/1600/Woodward_Harbor_LLC_et_al_v_City_of_Mandeville_et_al__laedce-23-05824__0117.0.pdf

What happened

Attorney John R. Walker admitted using generative AI to draft an opposition brief that contained at least eleven nonexistent, misquoted, or mischaracterized authorities. He filed the brief without verifying the citations, then failed to correct the errors after they were flagged. The court found a Rule 11(b)(2) violation, imposed personally on Walker rather than on the three other attorneys involved.

The rule and the sanction

Rule 11(b)(2) of the Federal Rules of Civil Procedure. The court ordered Walker personally to pay $1,000 and to complete two hours of generative-AI continuing legal education by December 31, 2026. The other three attorneys were not monetarily sanctioned.

How it could have been avoided

Verify every AI-generated citation against the original authority before filing. Treat an AI draft as a rough outline, not a citable brief. Correct known errors immediately instead of leaving them uncorrected.

Sources