Erin Booker v. The Kroger Co.
The case
Erin Booker v. The Kroger Co., N.D. Ga., No. 1:26-cv-02006-SDG, Judge Steven D. Grimberg, sanctions order August 28, 2026. Reported: https://www.mealeys.com/mealeys/articles/2521431/judge-imposes-8-000-sanction-against-attorney-for-use-of-ai (Sept. 3, 2026). The order identifies plaintiff's counsel only as "Mr. Johnson"; full name not confirmed in the sources reviewed.
What happened
Counsel filed fake/hallucinated and misrepresented authorities; at a hearing he denied using AI, then in his show-cause response admitted he had "consulted" AI, the court found repeated lies and repeated Rule 11 violations.
The rule and the sanction
Rule 11 violations found; $8,000 sanction payable to the court registry within 30 days, $1,000 for each of four fabricated/misrepresented authorities, doubled because of the lies. Counsel had claimed ethics/technology CLE; rather than ordering new CLE, the court ordered him to document all claimed courses within seven days, reserving whether further sanctions were warranted.
How it could have been avoided
Never deny AI use to a court that is asking, a false or evasive denial converts a competence failure into a candor problem and increases the sanction. If you are unsure what the court is asking about, say so plainly rather than improvising an explanation.