Chelsea Montes v. Suns Legacy Partners LLC
The case
Chelsea Montes v. Suns Legacy Partners LLC, D. Arizona, No. CV-25-01295-PHX-GMS, Document 73, order filed March 31, 2026. Copy of primary document: `files/sources/D-137-montes-v-suns-legacy-partners.pdf`. Source URL: https://www.damiencharlotin.com/documents/1872/Montes_v._Suns_Legacy_Partners_USA_31_March_2026.pdf
What happened
Attorneys Sheree Wright and Cortney Walters included at least 18 fictitious citations or fabricated quotations across four pleadings: the initial complaint, the response to the motion to dismiss, the reply in support of the anonymity motion, and a reply in support of a motion for leave to file out of time. The court found the citations had "all the markings of a hallucinated case created by generative artificial intelligence (AI) tools" and that "it is apparent that an LLM was used to conduct legal research, or even generate the initial complaint." Counsel blamed a law clerk, cite-checking tools, and clerical errors instead of verifying the authorities.
The rule and the sanction
Rule 11(b)(2) of the Federal Rules of Civil Procedure. The court held Wright, Walters, IBF Law Group, PLLC, and The Law Office of Cortney E. Walters, PLLC jointly liable for the defendant's reasonable attorneys' fees incurred in discovering the fictitious material and briefing the sanctions motion (amount to be set after fee briefing). It also required counsel to serve the order on their client, complete at least one hour of CLE on the ethical use of AI within 60 days, and directed the clerk to serve the order on the State Bars of Arizona and New Mexico, the Florida Bar, and all district and magistrate judges in the District of Arizona.
How it could have been avoided
Read every cited case yourself, because cite-checking tools do not catch hallucinated reporter numbers. Accept responsibility promptly instead of blaming staff or software, since courts weigh candor heavily. Complete AI-ethics training before using AI tools on filings, not after sanctions.