Case D-85 · AI Sanctions Case Tracker

Brooks v. Patel

Fourth Judicial District, Hennepin County, Minnesota, September 8, 2025

Response class R3, Half-Owned It

The case

Rayandre C. Brooks and Brooks Inc. v. Akshay (Roger) Patel, AAMCON Inc., Harsh Patel, Seema Hospitality LLC, Haresh Patel, and Oyo Hotel Pipestone aka Pipestone Inn, District Court, Fourth Judicial District, County of Hennepin, Minnesota, Court File No. 27-CV-24-11194, Order Imposing Sanctions for Use of Fake Legal Authority filed September 8, 2025 (Judge Christian Sande). Copy of primary document: `files/sources/D-85-brooks-v-patel.pdf`.

What happened

Attorney David Lutz, counsel for the defendants, filed supporting and reply briefs on the defendants' summary-judgment motion containing fake legal authority generated with an AI tool. (Plaintiffs' counsel was Taweh Anderson.) Lutz admitted using AI and failing to correct the hallucinated authority before filing.

The rule and the sanction

The court found violations of Minn. R. Civ. P. 11.02(b) and Minn. Stat. § 549.211, subd. 2(2), and sanctioned Lutz personally under Minn. R. Civ. P. 11.03. Sanctions: his supporting and reply briefs were stricken, a $5,000 monetary penalty was imposed against him personally, and he was referred to the Minnesota Lawyers Professional Responsibility Board.

How the lawyer responded

R3, Half-Owned It (the court raised the problem; Lutz admitted AI use in writing and at the hearing; remedial measures were described as underway but not itemized; he called the error unintentional; the order credits none of this and imposes $5,000 plus a bar referral).

How it could have been avoided

Verify every cited authority in an official reporter or trusted database before filing, especially any case surfaced by an AI tool. Read the full text of each cited opinion rather than relying on AI summaries. Disclose AI use in legal research and keep a written record of the verification steps taken.