Dehghani v. Castro
The case
Dehghani v. Castro, U.S. District Court for the District of New Mexico, April 2, 2025, No. 2:25-cv-00052-MIS-DLM, Doc. 28. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-64-dehghani-v-castro.pdf`.
What happened
Felipe D.J. Millan purchased a response brief from LAWCLERK attorney Janelle M. Lewis for $750, minimally edited it, and filed it without reading the case law or verifying the citations. The brief cited at least six non-existent cases that were "likely the handiwork of a ChatGPT or similar artificial intelligence (AI) program's hallucinations." Millan admitted he trusted the licensed LAWCLERK lawyer to perform the work in an ethical and competent manner.
The rule and the sanction
Violation of Federal Rule of Civil Procedure 11(b)(2), including improper delegation of the nondelegable duty to verify cited authority. Sanctions imposed on Millan: a $1,500 monetary sanction; completion of a one-hour CLE course on legal ethics or AI in writing; self-reporting to the New Mexico and Texas state bars; reporting Lewis to the New York disciplinary board; and sending a copy of the order to LAWCLERK. Source URL: the primary PDF (Charlotin documents archive: https://www.damiencharlotin.com/documents/310/Dehghani_v_Castro_USA_New_Mexico_April_2_2025.pdf).
How it could have been avoided
Never file a freelance attorney's work without reading and verifying every citation yourself; blind reliance on another lawyer is improper delegation. Budget time for a personal cite check on any outsourced brief. Self-report promptly if errors surface after filing.