Bevins v. Colgate-Palmolive Co.
The case
Bevins v. Colgate-Palmolive Co., U.S. District Court for the Eastern District of Pennsylvania, April 10, 2025, No. 25-576, 2025 WL 1085695. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-65-bevins-v-colgate-palmolive.pdf`.
What happened
Attorney Nicholas L. Palazzo cited nonexistent or mismatched authorities that appeared to be AI hallucinations "made up of parts of actual cases." He failed to comply with Judge Baylson's standing order on artificial intelligence, which required attorneys to certify that AI-assisted research was verified, and when ordered to submit an affidavit with copies of the judicial opinions cited, he failed to do so.
The rule and the sanction
Violation of Federal Rule of Civil Procedure 11(b)(2) and of the court's AI standing order. Sanctions: the sanctions order to be served on the Pennsylvania Bar and the Eastern District of Pennsylvania Bar (both of which Palazzo is a member of); Palazzo's appearance in the case stricken with prejudice; and Palazzo required to inform his client of the sanctions and that she must find new counsel if she refiles. The complaint was dismissed with leave to amend within 30 days. Source URL: the primary PDF (Charlotin documents archive: https://www.damiencharlotin.com/documents/244/Bevins_v._Colgate_Palmolive_US_DC_Eastern_Penn._April_10_2025.pdf).
How it could have been avoided
Comply with AI standing orders and disclosure requirements in every case assigned to a judge who has one. When ordered to produce cited opinions, produce them. Verify mismatched or unfamiliar authorities before relying on them, especially where real case names are spliced with wrong citations.