Mattox v. Product Innovations Research, LLC

Suzanna and Roger Mattox v. Product Innovations Research, LLC d/b/a Sunevolutions, Cosway Company, Inc., and John Does 1-3, No. 6:24-cv-00235-JAR, E.D. Okla., sanctions order (Document 148) filed October 22, 2025. Copy of primary document: `files/sources/D-98-mattox-v-product-innovations-research.pdf`.

Across eleven pleadings, plaintiffs' counsel submitted 28 false or misleading citations: 14 fabricated and 14 erroneous or misquoted. Drafting and signing attorney Harrison A. Howle admitted he used ChatGPT to "make his writing more persuasive," allowed it to alter citations, and filed the briefs without verification. Referring counsel T. Ryan Scott relied on the pleadings without questioning them, managing partner Sach D. Oliver authorized the referral and had no firm policy on AI use, and local counsel Gary R. Buckles lent his name to the filings as a favor without reviewing them.

The court sanctioned counsel under Federal Rule of Civil Procedure 11. Individual sanctions: Howle, $3,000 fine plus public reprimand; Scott, $2,000 fine plus public reprimand; Oliver, $1,000 fine plus public reprimand; Buckles, formal public reprimand plus a 12-month restriction on serving as sponsoring or local counsel for any pro hac vice attorney in the Eastern District of Oklahoma. The court also struck all eleven defective filings (docket entries 61, 72, 78, 89, 91, 92, 93, 94, 95, 101, 102), ordered verified amended pleadings with a signed certification of personal review within 60 days, and awarded $23,495.90 in attorney's fees and costs to defendants, to be reimbursed jointly and severally by the Howle Law Firm and the Oliver Law Firm in equal shares of $11,747.95 each (not borne by Buckles). No bar referrals were made.

Verify every citation in every pleading before filing, no matter how many filings are involved. Adopt and enforce a firm-wide policy requiring verification of all AI-assisted filings. Local and referring counsel should review pleadings submitted in their names rather than lending signatures as favors.