Case D-31 · AI Sanctions Case Tracker

City of Murfreesboro v. BFI Waste Systems of Tennessee, LLC

U.S. District Court for the Middle District of Tennessee, Memorandum Order August 6, 2026 (Magistrate Judge Luke A. Evans)

The case

City of Murfreesboro, Tennessee v. BFI Waste Systems of Tennessee, LLC, M.D. Tenn., No. 3:22-cv-00605, Memorandum Order filed August 6, 2026 (Magistrate Judge Luke A. Evans, Doc. 330), sanctioning attorney Louis W. Ringger III. Primary order: https://docs.justia.com/cases/federal/district-courts/tennessee/tnmdce/3:2022cv00605/91557/330/0.pdf ; reported: https://www.tennessean.com/story/news/courts/2026/09/07/artificial-intelligence-lawyers-court-risks/91337434007/

What happened

Per the account behind this entry, Ringger used Westlaw's AI-generated case-summary feature and quoted language from the AI summary as though it appeared in the judicial opinion itself, without checking the underlying opinion. The sanctions order itself (Doc. 330) names no tool and no mechanism; the mechanism is not established by the held record (Ringger's response, Doc. 328, is not held).

The rule and the sanction

Public reprimand and $1,500 monetary sanction against attorney Louis W. Ringger III for the Rule 11 violation.

How it could have been avoided

AI research summaries are starting points, not quotable authority: always open and read the underlying opinion before quoting or citing it, and never present a vendor's AI-summary language as the court's own words.

Sources