Case D-14 · AI Sanctions Case Tracker

Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC

U.S. District Court for the Southern District of Indiana, May 28, 2025 (Judge James Patrick Hanlon)

The case

Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC, S.D. Ind., May 28, 2025. Reported at: https://news.bloomberglaw.com/legal-ethics/lawyer-sanctioned-6-000-for-ai-generated-fake-legal-citations

What happened

Rafael Ramirez of Rio Hondo, Texas, representing an Indiana excavation company in a multiemployer-benefit-fund dispute, admitted using generative AI to draft briefs that included "hallucination cites" to at least three nonexistent cases (R&R, dkt. 99, at p. 8).

The rule and the sanction

Judge Hanlon imposed a $6,000 sanction, partially adopting Magistrate Judge Mark J. Dinsmore's recommendation, Dinsmore had urged $15,000 on the ground that prior AI sanctions "evidently failed to act as a deterrent." The $6,000 figure balanced deterrence against mitigation: Ramirez's efforts to educate himself on responsible AI use and the reputational harm he had already suffered. The court also referred Ramirez to the Indiana Attorney Disciplinary Commission (dkt. 103).

How it could have been avoided

Get the education before the violation, not after: complete AI-competence training before using generative AI on filings. Courts credit genuine remediation, but self-education after being caught only mitigates, it does not excuse, the failure to verify.

Sources