Court - Judge Name	Effective Date	Applicable To	Categories	Summary
Fed. Cl. -- Judge Eleni M. Roumel	10/15/2025	Generative AI	Generative AI Usage	In Polinski v. United States, 2025 WL 2935059 (Fed. Cl. Oct. 15, 2025), the pro se plaintiff included hallucinated citations (“cases that do not exist”) in his emergency motion for declaratory judgment and emergency motion to recognize and enforce express trust. The court reminded the plaintiff that Federal Rule of Civil Procedure 11(b) applies to attorneys and non-attorneys and “obligates any party appearing before this Court—including pro se litigants—t o, at a minimum, ‘confirm the existence and validity of[] the legal authorities on which they rely.” Judge Roumel noted that other courts have imposed sanctions for similar conduct but declined to do so here, as the plaintiff’s claims failed for lack of jurisdiction, and the defendant did not seek sanctions. However, the plaintiff was warned that sanctions could be imposed in the future for any future filings with “fictional, AI-generated legal authority.”
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
D.D.C. – Judge Amit P. Mehta	10/3/2025	Generative AI	Generative AI Usage	In Smith v. Athena Construction Group, Inc., No. 1:18-cv-02080-APM, Dkt. No. 201 (D.D.C. Oct. 3, 2025), the plaintiff-relator included citations to cases with incorrect legal propositions and fabricated quotations and one citation to a nonexistent case. Plaintiff-relator’s counsel admitted to using an unidentified GenAI tool to research legal authority to support his propositions but not checking the citations for accuracy. Dkt. No. 201 at 1-2. Judge Mehta viewed this attorney’s conduct to be both “reckless” and “singularly egregious” for solely relying on Lexis’s “protege AI product as a natural language search engine” (Dkt No. 196 at 2) to conduct legal research and relying on its output without checking its accuracy. Id. at 2. While the “prospects [of GenAI tools] are tantalizing,” attorneys must remain vigilant in reviewing cited authority for accuracy and cannot “ignore what we were all taught as first-years in law school.” Id. at 3. In light of this misuse, Judge Mehta ordered plaintiff-relator’s counsel to (i) pay the defendant’s attorney’s fees and costs incurred from the work to draft the underlying motion and reply brief and (ii) submit a copy of this opinion to the Pennsylvania Bar and notify this court of any subsequent disciplinary proceeding. Id. at 3-4.
			Applies to AI Used for Filings/Drafting
			Court-Imposed Consequences – Attorneys/Law Firms
D.D.C - Judge Reggie B. Walton	4/22/2025	Generative AI	Generative AI Usage	Judge Walton’s “General Order for Civil Cases” includes guidance on the “Use of Generative Artificial Intelligence.” Though parties are not prohibited from using GenAI, they must ensure that all representations of fact and the law are “complete and accurate.” Penalties for not doing so include sanctions under Federal Rule of Civil Procedure 11(c). Additionally, the guidance reminds attorneys of their “obligation to prevent the disclosure to unauthorized parties”—including GenAI tools—of “sensitive information,” such as medical, confidential, proprietary, or personal identifying information.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
District Court for the District of Columbia – Judge Rudolph Contreras	3/18/2025	Any AI	Any AI Usage	Judge Contreras warned a pro se plaintiff “against filing briefs with fabricated case citations” in Williams v. Cap. One Bank, N.A., 2025 U.S. Dist. LEXIS 49256, citing various cases addressing misuse of Gen AI in legal filings. He dismissed the action with prejudice, stating that the Plaintiff’s inclusion of nonexistent citations “dramatically weakens [plaintiff’s] opposition to [defendant’s] motion to dismiss because he fails to cite to supporting authority.” Although the decision does not use the term “generative AI,” the cases relied upon and the manner in which AI was purportedly used indicate that the court’s ruling is specific to AI used to “draft” legal filings in a manner which results in errors, and is thus likely targeted at Gen AI.
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
D.D.C. - Judge Randolph D. Moss	12/3/2024	Generative AI	Generative AI Usage	In Rubio v. District of Columbia, 2024 WL 4957373 (D.D.C. Dec. 03, 2024), the court noted that the pro se plaintiff used “seemingly fabricated cases” in his proposed second amended complaint, which included citations that “appear[ed] to have been “invented by artificial intelligence.” Although the court acknowledged that “there is no prohibition on using AI in this District,” and that GenAI “may be a valuable tool for pro se litigants in particular,” it warned plaintiff about the risks involved in using GenAI for litigation. The Court also observed that courts in other jurisdictions have imposed “Rule 11 sanctions for the improper use of AI assistance.” The court emphasized the importance of verifying the substance of filings through “reasonable [inquiries] . . . including verifying that every citation is real, and that “[t]he failure to do so is an abuse of the judicial system.” After this warning, the court proceeded to interpret the plaintiff’s proposed second amended complaint “liberally” despite its defects, though ultimately dismissed his federal law claims with prejudice given his “repeated fail[ure] to state a claim” despite “multiple opportunities to amend his complaint.”
			Suggests Cautious Use of AI
			Applies to AI Used for Filings/Drafting
Federal Trade Commission - Judge Ayoubi	9/13/2024	Generative AI	Generative AI Usage	Federal Trade Commission (“FTC”) Administrative Law Judge Ayoubi has been issuing scheduling orders in administrative cases with a requirement that attorneys or pro se litigants certify that either no portion of the filing was drafted by Gen AI or any portion that was drafted by Gen AI was “checked for accuracy by human attorneys or paralegals using printed legal reporters and/or online legal databases.” See, e.g., In the Matter of Asbury Automotive Group, Inc., et al. The order also cautioned that any filing that failed to comply with the certification requirement “may be stricken on that ground.”
			Requires Disclosure and/or Verification
			Applies to AI Used for Filings/Drafting

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