Case D-44 · AI Sanctions Case Tracker

Ramsey / Cruz v. Nelloms and Peachtree Truck Leasing Co., LLC

No. 2024CV04386, State Court of Clayton County, Georgia, sanctions order on/around January 14, 2026 (Judge Tammy Long Hayward)

The case

Cornelia Ramsey / ADA Melina Castan Cruz v. De'aaris M. Nelloms and Peachtree Truck Leasing Company, LLC, No. 2024CV04386, State Court of Clayton County, Ga., sanction order on/around January 14, 2026. Reported: https://www.law.com/dailyreportonline/2026/01/16/ga-judge-issues-25k-penalty-to-lawyer-citing-ai-hallucinated-cases/ (Jan. 16, 2026); defense filing documenting the fabricated citations (ALM asset): https://assets.alm.com/c4/9a/6ee2da8d41c69226d30916652a36/defendants-response-in-opposition-to-plaintiffs-motion-to-amend-or-withdraw-admissions-with-exhibits4927-2221-34751.pdf

What happened

Plaintiff's counsel Tristan Gillespie filed multiple briefs (opposition to motion to open default, opposition to summary judgment, motion to withdraw admissions) containing fictitious, hallucinated, or grossly misrepresented case citations generated by an AI application, e.g., "Kaplan v. Banks" (no such Georgia case), "Cox v. Webb" (nonexistent), plus wrong pin cites and opposite holdings on real cases (Porter v. Urban Residential Dev. Corp., Flanders v. Hill Aircraft, Arnold v. Neal, Rowland v. Tsay). At an August 20, 2025 hearing he did not deny the briefs were genAI-drafted and offered no explanation. Judge Hayward called the brief "essentially fiction."

The rule and the sanction

Sanctions under OCGA § 9-15-14 (filings lacking substantial justification), with defense counsel also invoking Ga. R. Prof. Cond. 3.3 (candor) and 3.4. Personal sanction against Gillespie of $25,498.08 (reported by Law.com as a "$25K penalty"; the exact figure comes from secondary hearing reporting, treat as approximate) payable to opposing counsel (Luke Kennedy of McMickle, Kurey & Branch) for time and fees spent chasing the fake citations. The court declined to dismiss the case with prejudice.

How it could have been avoided

Verify every citation exists and supports the proposition, pull each opinion and check the pin cite and holding. When the court flags citation problems, respond candidly with corrected citations rather than silence; declining to explain converts suspicion into a maximum sanction. (Separate overdue-discovery sanction requests in the same case compounded the judge's view of the conduct.)

Sources