Case D-30 ยท AI Sanctions Case Tracker

Gauthier v. Goodyear Tire and Rubber Co.

U.S. District Court for the Eastern District of Texas (Wyoming matters covered under D-51)

Repeat offender (verified in the record)

The case

(a) Gauthier v. Goodyear Tire & Rubber Co., E.D. Tex., No. 1:23-cv-00281, sanctions order (Doc. 48): $2,000 penalty plus continuing legal education responsibilities. Primary order: https://cases.justia.com/federal/district-courts/texas/txedce/1:2023cv00281/223848/48/0.pdf?ts=1732629142 ; (b) AI-hallucinated filings before a Wyoming federal judge are covered under D-51 (Wadsworth v. Walmart); no separate D-30 Wyoming file was kept. Both reported in Bloomberg Law coverage: https://news.bloomberglaw.com/legal-ethics/lawyer-sanctioned-over-ai-hallucinated-case-cites-quotations

What happened

Both matters involved AI-hallucinated filings submitted without verification.

The rule and the sanction

(a) E.D. Tex. (Gauthier): $2,000 penalty plus continuing legal education responsibilities, and an order to provide a copy of the sanctions order to the client and to file a certification on the docket attesting that he had done so within 21 days (ORDER, p. 6). (b) Wyoming: see D-51 (Wadsworth v. Walmart, D. Wyo., Feb. 24, 2025): $3,000 plus pro hac vice revocation for Rudwin Ayala, and $1,000 each for T. Michael Morgan and Taly Goody.

How it could have been avoided

Even "smaller" sanctions now routinely include compelled AI education: complete such training voluntarily before using the tools. Captions for the Goodyear matter beyond Gauthier v. Goodyear were not captured in available coverage; it is included here as a reported enforcement data point.

Sources