Daniel Gentry v. Calvin Thompson
The case
Daniel Gentry v. Calvin Thompson, E.D. Louisiana, Civil Action No. 25-1260, order dated March 20, 2026, 2026 WL 787563. Copy of primary document: `files/sources/D-133-gentry-v-thompson.pdf`. Source URL: https://www.damiencharlotin.com/documents/1771/Gentry_v._Thompson_USA_20_March_2026.pdf
What happened
Attorney Jalen Harris admitted using ChatGPT and failing to check nine hallucinated citations in a filed brief. His supervisor, James Roquemore, failed to exercise supervisory oversight over the filing. Corwin St. Raymond was also involved but received only an admonishment.
The rule and the sanction
Rule 11 of the Federal Rules of Civil Procedure. The court imposed a $250 sanction personally against Harris and a $1,000 sanction against his supervisor, James Roquemore. St. Raymond received a formal admonishment rather than a monetary sanction.
How it could have been avoided
Supervisors must verify AI-assisted filings before signing off on them. Check every citation, including pinpoint pages and quoted language. Treat hallucinated citations as a supervisory failure, not just an associate's mistake.