A federal judge gave two lawyers representing internet provider Uprise an unusual choice after a court filing contained at least 14 apparently fictitious case citations and other misquoted or misrepresented authorities. According to reporting by Futurism, the alternatives included paying $2,500 each while risking removal from the case and a state-bar referral, or publicly explaining the error to legal and academic institutions and helping educate other lawyers about artificial-intelligence risks.
The word “humiliating” is a headline characterization, not a neutral legal finding. The available account describes a proposed or conditional remedy; it does not establish that every listed consequence was ultimately imposed.
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What happened in the Cozen O’Connor case?
Judge David Hardy was overseeing a federal case in which Cozen O’Connor lawyers represented Uprise, an internet service provider. The court found at least 14 apparently nonexistent case citations in a filing, along with real authorities that were quoted or described inaccurately.
Futurism’s account says associate Daniel Mann used ChatGPT to help draft and edit an early, uncorrected version that was accidentally filed. Those details come from news reporting and firm-related statements, rather than a primary court order reproduced here. The same account reports that Mann was fired and that co-counsel Jan Tomasik apparently remained at the firm.
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The available coverage does not establish whether Uprise’s case was delayed, whether the filing was formally struck or replaced, or whether the court found intentional deception. Readers should not infer criminal conduct, disbarment, or a final merits ruling from the sanctions episode.
For context on professional obligations, see the American Bar Association’s analysis of legal AI ethics.
What was the judge’s unusual punishment option?
As reported, the judge described two paths for each lawyer:
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- Financial and disciplinary exposure: pay $2,500, risk removal from the case, and face referral to the relevant state bar.
- Public remediation: avoid that combination by writing to law-school deans and bar officials about the misconduct, offering to speak or write publicly about AI and professional responsibility, and participating in related educational or continuing-legal-education work.
That structure is why coverage called the remedy humiliating: it could require the lawyers to explain their own failure to professional and academic audiences. It is more precise to describe it as a proposed alternative involving public education, rather than as a completed punishment. The available reporting does not confirm which option, if any, the lawyers accepted or whether a later final order changed the terms.
What is an AI hallucination in a legal filing?
Generative AI produces text that sounds authoritative but is not guaranteed to be true. In legal work, a hallucination can take several forms:
- A completely fabricated case, docket number, quotation, or citation.
- A real decision paired with an invented quotation.
- A real authority attributed to the wrong court or judge.
- A holding that is misstated, overstated, or stripped of its limiting facts.
- A citation-format error that makes the source difficult to locate.
- A summary that omits the case’s procedural posture, dissent, dicta, or later overruling.
A polished citation is not proof that a case exists. A lawyer must open the underlying authority and determine that it supports the exact proposition being filed.
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The separate Walmart sanctions case
The Uprise matter is distinct from Wadsworth v. Walmart, a Wyoming case involving three plaintiffs’ lawyers. The court’s sanctions order is available at LawNext, and the decision is reproduced at FindLaw.
| Issue | Cozen O’Connor/Uprise matter | Wadsworth v. Walmart |
|---|---|---|
| Lawyers | Two defense lawyers | Three plaintiffs’ lawyers |
| Problematic authorities | At least 14 apparently fictitious citations, plus misquotations or misrepresentations | Eight of nine cited cases did not exist |
| AI system reported | ChatGPT, used by associate Daniel Mann in drafting or editing, according to reporting | MX2.law, an in-house firm database identified in the sanctions order |
| Reported remedy | $2,500-per-lawyer alternative, with possible removal and bar referral, or public educational remediation | Rudwin Ayala removed as counsel of record and fined $3,000; T. Michael Morgan and Taly Goody fined $1,000 each |
| Firm sanctions | Firm policy and personnel consequences are reported; a final court sanction is not established here | Morgan & Morgan was not separately sanctioned after the court considered its training and remedial measures |
In Wadsworth, the lawyers admitted on February 10, 2025, that the nonexistent authorities were AI hallucinations. The court said signing attorneys must make a reasonable inquiry into the law and cannot delegate that obligation to software or junior staff.
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Why courts treat fabricated authority seriously
Courts rely on lawyers to present an accurate legal record. Fake cases and invented quotations can waste judicial and opposing-counsel resources, misstate what a judge has held, prejudice a client or opponent, and distort the analysis of the dispute.
Federal Rule of Civil Procedure 11 requires an attorney who signs a filing to certify, after a reasonable inquiry, that legal content is supported by existing law or a nonfrivolous argument for changing it. The Wadsworth order explained that a nonexistent opinion is not existing law and that citing one can violate Rule 11(b)(2). “The AI made it up” therefore does not transfer responsibility away from the signer.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Is using AI prohibited for lawyers?
No general ban on AI use follows from these cases. The critical distinction is between using software as an assistive tool and filing unverified output. Brainstorming, formatting, or summarizing a verified source may be compatible with professional practice, subject to confidentiality and court rules. Unsupported citations, invented quotations, and inaccurate procedural histories are not.
Traditional databases do not eliminate review either. A lawyer remains responsible for checking work produced by a legal-research platform, an in-house system, a junior associate, or a generative model.
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What lawyers should verify before filing
- Confirm that every cited case, statute, regulation, docket number, reporter reference, and pinpoint citation exists.
- Open the original source and check that every quotation is word-for-word accurate.
- Determine whether quoted language comes from the holding, dicta, a dissent, a party’s brief, or an overruled decision.
- Confirm that the court, jurisdiction, date, and procedural posture make the authority relevant.
- Check that the authority supports the precise proposition for which it is cited, not merely a related topic.
- Review statutory and regulatory citations for current versions.
- Check the filing for invented facts, parties, dates, or procedural history.
- Require the lawyer who will sign to read and approve the final document.
- Keep confidential or privileged client information out of unauthorized public AI tools.
What can affect the severity of sanctions?
Sanctions are not automatic or identical. Courts may weigh whether counsel promptly admitted the error, withdrew or corrected the filing, reimbursed unnecessary costs, misled the court after discovery, repeated the conduct, caused actual prejudice, had access to reliable research tools, maintained AI training and policies, or had a disciplinary history.
In Wadsworth, the court credited transparency, apologies, withdrawal of the motions, payment of opposing counsel’s fees, and new safeguards, while still imposing individual sanctions. That result illustrates why firm policies can mitigate institutional penalties without excusing the lawyer who signs an unverified filing.
What remains unknown in the Uprise matter?
- Whether the lawyers selected the $2,500 payment option or the public-education alternative.
- Whether removal from the case or a state-bar referral actually occurred.
- Whether a final sanctions order was entered with different terms.
- Whether the filing was withdrawn, corrected, or struck, and whether Uprise incurred measurable delay or additional expense.
Until a final order or docket record answers those questions, the safest account is that Judge Hardy presented an unusually public corrective option after an allegedly AI-assisted filing contained fabricated and misrepresented authorities.
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