U.S. District Judge Sharion Aycock removed all four attorneys from a contract dispute in the Northern District of Mississippi after finding that both legal teams submitted filings containing fictitious case citations generated by artificial intelligence. The ruling establishes strict consequences for counsel who fail to verify Generative AI and LLM outputs before filing them with a federal court.
Total removal and sanctions
On June 8, Judge Aycock issued sanctions that cleared both legal teams from the case entirely. She barred two of the attorneys from appearing before Northern District courts for two years. The underlying dispute involves a contract claim between attorney Tom Withers and the city of Aberdeen over unpaid legal fees.
"This case presents the Court with an unusual scenario-attorneys for both litigants engaged in similar sanctionable conduct," Aycock wrote in her ruling. "Their practice of blindly relying on technology resulted in the hallucinatory citations contained in their respective filings."
Rule 11 violations and ignored warnings
The judge found that all four lawyers violated Rule 11 of the Federal Rules of Civil Procedure, which requires attorneys to conduct a reasonable inquiry to confirm that legal claims and citations are warranted. Aycock had previously notified the lawyers of her concerns in a December 2023 order, giving them a chance to defend their choices at a January 2024 hearing.
Despite this warning, the attorneys filed corrected documents only after the court raised the issue. During testimony, out-of-state attorneys Kathleen Wilson and Kathryn Young Williams admitted to using AI tools for research and drafting. Local counsel Shauncey Hunter Ridgeway and Mark McClinton testified they did not use AI but admitted to signing memorandums without checking the underlying sources.
Bad faith and policy violations
Aycock singled out Williams for acting in bad faith. Williams' firm maintains an internal policy requiring lawyers to independently verify AI software outputs. The judge noted that Williams knew the software was not designed to produce Mississippi case law but used it anyway.
"If it were ever an excuse to plead ignorance of the risks associated with the use of generative AI in legal filings, that time has passed," Aycock said. The court also noted that Williams previously faced sanctions in a separate U.S. Bankruptcy case in March for submitting filings with AI hallucinations, just two months after apologizing to Aycock's court in this matter.
The judge also found that Williams misrepresented her schedule to avoid appearing at the show-cause hearing. Because Wilson and Williams were practicing in Mississippi under pro hac vice status, Aycock questioned their ability to continue practicing in the state, describing such admission as a privilege subject to revocation.
The judge credited local counsel Ridgeway and McClinton for accepting responsibility and self-reporting to the Mississippi Bar, though she noted their omissions were still negligent. "The Court appreciates her efforts in attempting to remediate the issue and her acceptance of responsibility, but finds that those factors do not shield her from being sanctioned," Aycock said regarding Ridgeway's post-hearing analysis.
Why this matters for legal professionals
Federal courts are moving past warnings and actively enforcing sanctions against attorneys who treat AI outputs as verified legal research. Relying on local counsel to sign off on out-of-state filings does not absolve the drafting attorney of Rule 11 obligations. Legal teams must implement and enforce mandatory, human-led verification steps for any AI-generated citations before they reach a court docket.
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