Lafontant v. Coolidge-CLK St. Germaine, LLC

Robenson Lafontant v. Coolidge-CLK St. Germaine, LLC, et al., Civil Action No. 24-2536, Section E (4), E.D. La., Order and Reasons (Document 53) filed October 3, 2025, order dated October 2, 2025 (Judge Susie Morgan). Copy of primary document: `files/sources/D-92-lafontant-v-coolidge-clk.pdf`.

Attorney Pius A. Obioha, counsel for plaintiff, signed and filed a memorandum in opposition to a motion for partial summary judgment without verifying its citations. The brief cited a fabricated, AI-generated case. He told the court a law clerk had prepared a first draft, but he never confirmed the accuracy or even the existence of the authorities.

The court found a violation of Federal Rule of Civil Procedure 11(b)(2) and imposed sanctions under Rule 11(c)(5)(B): a $1,000 fine payable personally by Obioha (not by his firm or the plaintiff) to the Clerk of the Court by November 3, 2025; one hour of continuing legal education on the topic of generative AI by January 31, 2026, with proof of attendance filed with the court; and referral to the Disciplinary Committee of the U.S. District Court for the Eastern District of Louisiana.

Personally read and confirm the existence of every cited case, including those drafted by a law clerk or assistant. A signature on a brief is a certification that the authorities were checked. Take at least a short CLE on generative AI before relying on any AI-assisted research workflow.