| Court - Judge Name |
Effective Date |
Applicable To | Categories | |
| N.D. Ga. – Magistrate Judge Regina D. Cannon | 7/28/2025 | Generative AI |
Generative AI Usage | In Ra’Kisha King v. J.B. Hunt Transport, Inc., No. 1:23-cv-3597, ECF No. 95 (N.D. Ga. July 28, 2025), the pro se plaintiff included “what appears to be a hallucinated case citation” in her motion for leave to file excess pages in support of her forthcoming motion for partial summary judgment. The court reminded the parties that all filings are subject to Federal Rule of Civil Procedure 11(b) and thus must verify the accuracy of all submitted briefing. As a result, “[u]nverified AI use does not meet the requisite standard.” Magistrate Judge Cannon declined to impose sanctions but instead ordered the pro se plaintiff to submit a declaration with any future filing that discloses the use of any GenAI tool; identifies which portions, if at all, were drafted with GenAI; and certifies that all assertions are checked and accurate. If the plaintiff fails to include this certification, the court warned that her filing will be stricken from the record. Further, if the plaintiff makes future misrepresentations of case law, she may face sanctions and case dismissal. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| M.D. Ga. – Judge W. Louis Sand | 7/14/2025 | Generative AI |
Generative AI Usage | In Jackson v. Auto-Owners Ins. Co., 2025 U.S. Dist. LEXIS 133070 (M.D. Ga. July 14, 2025), counsel for the plaintiff cited nine hallucinated cases in his response to the defendant’s motion to dismiss. Counsel admitted to using AI software to assist in drafting the response but remarked that the AI-generated version “was supposed to be used only as a framework” and “was never intended to be filed.” He further apologized to both the court and defense counsel for the time spent reviewing the hallucinated citations and remarked that his law firm was understaffed around the time of the filing. In assessing whether to sanction the plaintiff’s attorney, Judge Sands highlighted the attorney’s failure to either provide a sworn declaration about the creation of the false citations or to even mention the false citations in his initial response to the order to show cause. The court determined that dismissing the case in its entirety would be too harsh, as it would “impose unwarranted sanctions” on the plaintiff. Instead, Judge Sands ordered the plaintiff’s attorney to (i) pay a $1,000 fine, (ii) complete a CLE course on AI within 90 days of the order, (iii) pay the defendant’s attorneys’ fees and costs associated with the review of the hallucinated cases and the attendance of the show cause hearing, and (iv) serve a copy of this order on the Chief Judge of each federal district court in Georgia. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties – Attorneys/Law Firms | ||||
| Fulton Cnty. Sup. Ct., Ga. – Judge Craig L. Schwall Sr. | 7/11/2025 | Any AI | Any AI | Judge Schwall Sr. of the Georgia Fulton County Superior Court issued a standing order that “governs the use of artificial intelligence (‘AI’) tools in the preparation of all briefs, proposed orders, and other written submissions” filed before the court, applicable to both attorneys and pro se litigants. The standing order requires that individuals who use “AI in any capacity to prepare, draft, or review a filing” must disclose the specific AI tools used and certify that the filing (including “every citation”) has been independently reviewed for accuracy. Failure to comply with the disclosure requirement may result in various penalties, including sanctions and dismissal. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting | ||||
| S.D. Ga. – Judge J. Randall Hall | 4/23/2025 | Generative AI |
Generative AI Usage | In Nichols v. Walmart, Inc., 2025 WL 1178592 (S.D. Ga. Apr. 23, 2025), the court sanctioned the pro se plaintiff for her use of fabricated legal citations in a motion to disqualify opposing counsel. The court found that the plaintiff cited “nonexistent legal authority” and failed to provide “any meaningful explanation” for such citations, despite being given an opportunity to respond to a show-cause order regarding potential Rule 11 sanctions. Citing the need to deter similar conduct, the court determined that dismissal of the case was an appropriate nonmonetary sanction, particularly considering the plaintiff’s indigency. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| M.D. Ga. Judge C. Ashley Royal | 4/8/2025 | Any AI | Generative AI Usage | In Gordon v. Wells Fargo Bank N.A. Inc., 2025 U.S. Dist. LEXIS 66601, the court considered whether to impose Rule 11 sanctions as a result of the pro se plaintiff citing multiple cases “that appear to be fake.” Although reiterating that that “there is no general prohibition on using AI during the course of litigation,” the court ordered that the plaintiff “must verify that any case he cites is in fact real, and not AI-generated.” The court further warned the plaintiff that he may incur a “substantial penalty” if he fails to comply with Rule 11, but did not impose sanctions. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| ND Ga. – Judge Johnson | 2/8/2025 | Any AI | Any AI | Judge Johnson’s standing order requires all counsel and pro se parties to disclose the use of “artificial intelligence (AI) in any capacity to prepare documents submitted to the Court.” The order provides template language for the certification, which would require disclosure of the specific AI tool used and certification that the signer “independently reviewed this document to confirm accuracy, legitimacy, and use of good and applicable law, pursuant to Rule 11 of the Federal Rules of Civil Procedure.” The order also advises counsel and pro se parties that “mistake, lack of technical expertise, and time constraints are typically not recognized by the Court as a good faith excuse for submission of documents that either violate Rule 11 or this disclosure rule,” specifically states that arguments “supported by AI-generated caselaw (i.e., cases that do not actually exist) are not acceptable,” and cautions that failure to comply with the order may result in appropriate sanctions, up to and including dismissal and/or default judgment. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting | ||||
| N.D. Ga. – Magistrate Judge Regina D. Cannon | 6/5/2024 | Generative AI | Generative AI Usage | In Leslie v. IQ Data Int’l, 2024 U.S. Dist. LEXIS 99970 (N.D. Ga. June 5, 2024), the pro se plaintiff cited non-existent case law in various filings, even after the defendant raised concerns about their existence. The plaintiff also represented to the court during a hearing on the motions that “it was his belief he was citing good case law” and provided no other reasoning for their inclusion, which the court concluded was indicative of bad faith. Because of the plaintiff’s use of fictitious citations and the failure to comply with discovery requests, the court granted the defendant’s motion for sanctions but found that monetary penalties would be inappropriate given plaintiff’s financial situation. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| S.D. Ga. – Magistrate Judge Christopher L. Ray | 10/6/2023 | Generative AI | Generative AI Usage | In Thomas v. Pangburn, Magistrate Judge Ray issued an report and recommendation (which was adopted by the district court; the 11th Circuit dismissed an appeal of that order) ordering dismissal of a pro se plaintiff’s amended complaint because the plaintiff cited to ten cases in his briefing “that simply did not exist.” The court ordered the plaintiff to show cause why he should not be sanctioned. When the plaintiff failed to explain “what sources he relied on during his research or where he found the sham cases,” the court concluded that both the “fictitious citations” and plaintiff’s failure “to explain their origin” warranted dismissal “as a sanction pursuant to Rule 11(b)” because such conduct demonstrated “bad faith.” Although the order does not explicitly mention “AI,” the order’s reasoning would likely apply to any “fictitious citations,” no matter their source. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties |




