Federal Court Sanctions Law Firm for AI-Generated Citations That Do Not Exist

Federal Court Sanctions Law Firm for AI-Generated Citations That Don't Exist — Including From Its Own Complaint

A Tennessee federal court issued sanctions against a law firm for repeatedly submitting court filings containing fabricated citations generated by AI — including quotes that do not appear in the cited authorities, and paragraph references to the firm's own complaint that do not exist.

In Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz PC (No. 2:25-cv-2623-SHL-atc, W.D. Tenn., June 2, 2026), Chief U.S. District Judge Sheryl H. Lipman found Reaves Law Firm violated Federal Rule of Civil Procedure 11. The irony: RLF is suing a defendant law firm for legal malpractice.

Key Takeaways

• Nine problematic citations, not one. Opposing counsel identified nine authorities that either did not support the arguments made or contained quotes that do not exist in the source material.
• The pattern continued after being flagged. Within days of defendants raising concerns, RLF filed additional pleadings with the same issues — this time citing nonexistent paragraphs from its own complaint.
• Sanctions were public and professional. The court ordered RLF to reimburse defendants' costs, forward the sanctions order to other district judges, and notify the Tennessee Board of Professional Responsibility's Disciplinary Counsel.

RLF described the errors as a "procedural lapse" caused by operational strain. The court's response: "Neither request is well taken."

Read the full article on National Law Review