Mortazavi v. Booz Allen Hamilton, Inc.
The case
Mortazavi v. Booz Allen Hamilton, Inc., U.S. District Court for the Central District of California, October 30, 2024, No. 2:24-cv-07189-SB-RAO, Doc. 48. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-61-mortazavi-v-booz-allen.pdf`.
What happened
Plaintiff's counsel used undisclosed generative AI in a motion to remand that contained a fabricated case and fabricated quotations attributed to the complaint. The court found repeated violations of its rules and orders, including the judge's AI-disclosure standing order, and warned that counsel had been admonished on prior filings rather than issued an OSC.
The rule and the sanction
Violation of Federal Rule of Civil Procedure 11 and the judge's AI-disclosure standing order. Sanctions: a $2,500 monetary sanction payable into the Fiscal Section of the Clerk's office, and mandatory notification to the California State Bar of the sanction, with a copy of the order attached. Proof of payment and notification to be filed by January 3, 2025. The order does not name counsel, so no attorney name is included. Source URL: the primary PDF (Charlotin documents archive: https://www.damiencharlotin.com/documents/245/Mortazavi_v._Booz_Allen_Hamilton_US_DC_Central_California_October_30_2024.pdf).
How it could have been avoided
Disclose generative AI use whenever a standing order or local rule requires it. Read every quotation against the underlying source before filing; fabricated quotations are indefensible under Rule 11. Treat prior admonishments as the last warning they are.