Lipe v. Albuquerque Public Schools

Tatia Lipe v. Albuquerque Public Schools, Civ. No. 23-899 GBW/JMR, D.N.M., Sanctions Order (Document 149) filed September 22, 2025. Copy of primary document: `files/sources/D-88-lipe-v-albuquerque-public-schools.pdf`.

Attorney Boglarka Foghi, counsel for plaintiff, admitted that unreviewed AI use by her paralegal and another contractor was the only explanation for nonexistent cases and fictional quotations appearing in her briefing. She filed the brief without checking the authorities herself.

The court found a violation of Federal Rule of Civil Procedure 11(b)(2) and ordered sanctions: a $3,000 fine against Foghi personally and mandatory self-reporting to the New Mexico and Arizona bar disciplinary boards. The Arizona self-report resulted in formal discipline: by Order Accepting Agreement for Discipline by Consent (In re Boglarka Foghi, State Bar No. 037059, June 10, 2026), the Presiding Disciplinary Judge of the Supreme Court of Arizona imposed a reprimand and six months of probation (with LOMAP consultation and $1,200 in costs) for the conduct in this case. (per the Arizona order, located at Stage 2)

Supervising attorneys are responsible for work product from paralegals and contractors, so verify AI-assisted drafts the same way as associate work. Require every citation in a filed brief to be checked against the original opinion. Maintain a firm policy that staff must disclose when AI tools were used to generate research or drafts.