Hi TCPAWorld!
Not only is generative AI not your friend, but it is also not your colleague, advisor, or trusted resource. In the practice of law, it is (more often than not) your enemy.
In a recent case out of the Westen District of Tennessee, the use of generative AI was once again a costly mistake. In Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz PC, Jonathan Hancock, Mary Katherine Campion, Jerrick Murrell, and Dean J. Shauger, 2:25-cv-2623-SHL-atc (W.D. Tenn. June 2, 2026), Chief U.S. District Judge Sheryl H. Lipman issued significant sanctions against the plaintiffs, Reaves Law Firm (“RLF”), for violating Federal Rule of Civil Procedure 11 for its improper use of generative AI in its filings.
The parties to this matter are both law firms, and, ironically enough, RLF is alleging causes of action against Defendants for legal malpractice. After RLF filed a Partial Motion to Dismiss, Defendants called into question RLF’s use of generative AI in its filings. Particularly, Defendants point out that RLF not only cited authorities that do not support their arguments, but they also cited quotations from those authorities that do not exist. And it wasn’t just one or two problematic cites. Defendants identified nine problematic authorities RLF relied upon in their filings.
Within days of Defendants raising these concerns, RLF filed two additional pleadings that included similar issues. These subsequent filings are arguably even more concerning as RLF cited facts and paragraphs from their own complaint that do not even exist.
After Defendants alerted the Court to RLF’s suspected use of generative AI, the Court issued an Order to Show Cause to identify why the Court should not impose sanctions and to offer proof that the authorities they cite actually exist, whether each authority stands for the argument RLF cites, confirm the quotes actually come from the cited authorities, and the steps RLF took to verify the existence of the authorities prior to citing them.
In their response to the Order to Show Cause, RLF failed “to do almost everything that the Court required it to do.” Instead, RLF claimed the errors in their filings were purely clerical and neither substantive nor misleading. Further, RLF classified their “clerical error” as a mere “procedural lapse” due to “extraordinary operation strain,” which they alleged was ultimately caused by the verdict against RLF that initiated the current lawsuit against Defendants. RLF requested that the Court “accept this Response as good cause” and to “decline to impose sanctions that would effectively reward Defendants for their misconduct.”
The Court’s response: “Neither request is well taken.”
The Court issued three significant sanctions to “reflect the serious nature of RLF’s ethical lapses.” Specifically, the Court ordered RLF to reimburse Defendants for costs associated with responses to RLF in this matter and to forward the Order Issuing Rule 11 Sanctions to other judges in the District as well as to the Tennessee Board of Professional Responsibility’s Disciplinary Counsel.
The lesson here is clear: generative AI has no place in the practice of law. Which is exactly why Troutman Amin, LLP has a “Zero Tolerance” Policy for AI usage by its attorneys.
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