Medical Buyers Group, LLC d/b/a Integrity v. Candice Pence, et al.
The case
M.D. Ga., No. 3:25-cv-00105-TES: public admonishment order November 18, 2025 (Doc. 52) and attorney's-fees sanctions order January 20, 2026 (Doc. 66). Primary orders: https://cases.justia.com/federal/district-courts/georgia/gamdce/3:2025cv00105/137850/52/0.pdf?ts=1763543778 ; http://storage.courtlistener.com/recap/gov.uscourts.gamd.137850/gov.uscourts.gamd.137850.66.0.pdf
What happened
Counsel for plaintiff Medical Buyers Group, LLC d/b/a Integrity (identified in the orders as Jason Gordon) admitted using hallucinated cases in responses to motions to dismiss. Before the hearing he took extensive corrective steps: informing the client, requesting defendants' fee amounts, verifying all remaining citations, preparing amended responses, changing his firm's citation-verification procedures, and completing a CLE course on "Common AI Mistakes."
The rule and the sanction
The court publicly admonished Gordon for submitting hallucinated and false case citations without authenticating them (Rule 11(b)(2) violation), then ordered him to pay $10,000 in attorney's fees as sanctions, $5,000 to counsel for P4 Biologix and Lisa Pence and $5,000 to counsel for Candice Pence, within 60 days. Because Rule 11's procedural requirements were not satisfied, the court imposed the fees under its inherent authority, holding that citing hallucinated cases constitutes bad faith even when unintentional. The court credited Gordon's ownership of the mistake as the reason the sanction was limited to fees.
How it could have been avoided
Prompt, complete ownership plus documented remediation caps the damage, but does not eliminate it: unintentional hallucinations are still sanctionable bad faith under inherent authority. Fix the firm's verification procedures the first time, not after the show-cause order.