Docket entry 21, 14 July 2025 · source · PDF · 9 pages
Docket text. ORDER The Court has carefully considered the applicable rules, case law, Mr. Braddy's conduct, his Declaration, the comments and arguments of counsel at the Show Cause Hearing, and the entire Record. Having considered the totality of the circumstances and facts, the Court finds that sanctions should be imposed. Ordered by US DISTRICT JUDGE W LOUIS SANDS on 7/11/2025. (ksl) (Entered: 07/14/2025)
1 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA VALDOSTA DIVISION WOODROW JACKSON, Plaintiff, v. AUTO-OWNERS INSURANCE COMPANY, Defendant. __________________________________________ : : : : : : : : CASE NO: 7:24-cv-136–WLS ORDER The Court held a show cause hearing on June 3, 2025, with respect to why Plaintiff’s counsel, Brian Braddy, should not be sanctioned for citing non-existent or “hallucinated” cases to the Court and Defendant’s counsel in Plaintiff’s Response to Brief in Support of Denying Defendant’s Motion to Dismiss (Doc. 9) (“MTD Response”) filed April 7, 2025.
In Auto-Owners’ Reply (Doc. 10), its counsel pointed out that they could not locate any of the cases/opinions cited in the MTD Response. (Id. at 2).
P. 11(b), (c); 28 U.S.C. § 1927;1 and/or the inherent power of the Court for citing non-existent cases to the Court. The written explanation 1 28 U.S.C. § 1927 provides: “Any attorney or other person admitted to conduct cases in any court of the United States or any Territory thereof who so multiplies the proceedings in any case unreasonably and vexatiously may be required by the court to satisfy personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” 2 was ordered to be in the “form of a sworn declaration providing a thorough explanation of how the [MTD] Response and nonexistent cases were generated.” (Doc.
13 at 3 (emphasis added)). The Court cautioned that it would not hesitate to impose Rule 11 sanctions against a party who abuse d the adversary process or otherwise attempt ed to deceive the Court by relying on nonexistent case law. Plaintiff’s Response to Order to Show Cause and Motion to Substitute Correct Legal Authorities (Doc.
In addition to reiterating the information in the Declaration at the hearing, Mr. Braddy personally apologized to the Court and Auto- Owners’ counsel for the additional time and work caused by filing the MTD Response with the hallucinated citations. As an explanation, but not an excuse, Mr.
While Mr. Braddy believed he had discussed the incorrect signature block and the hallucinated citations with Auto-Owners’ counsel and that a corrected MTD Response had been filed, he did not realize that the corrected version had not been filed until he received the Court’s Show Cause Order. Auto-Owners’ counsel advised the Court that in their interactions with Mr.
While Auto-Owners’ counsel stated they had discussed the incorrect signature block with Mr. Braddy, they advised the Court that they had not discussed the hallucinated citations with him and were unaware of the problems with the citations until they reviewed the MTD Response in preparing to file a reply if necessary. was expecting from Mr. Braddy.
LAW AND ANALYSIS In sum, this is a case where it is clearly established and admitted that Mr. Braddy utilized AI to prepare the MTD Response which contained multiple hallucinated case citations . Although Mr.