Louisiana

Court - Judge Name

Effective Date

 Applicable To Categories

Summary

 W.D. La. – Judge Terry A. Doughty   11/24/2025 Generative AI   Generative AI Usage In Mills v. Rocket Mortg. LLC, 2025 U.S. Dist. LEXIS 231080 (W.D. La. Nov. 24, 2025), the court adopted the magistrate judge’s report and recommendation, and warned the plaintiffs of sanctions, including “the striking of their briefs, fines, or other appropriate actions” if they misuse GenAI tools in future filings. In doing so, Judge Doughty referred to the preceding report and recommendation issued by Magistrate Judge Kayla Dye McClusky that highlighted the plaintiffs’ presumed use of GenAI given their citations to nonexistent cases, inaccurate citations, and “mischaracterizations of cases which do exist.” See Mills v. Rocket Mortg. LLC, 2025 U.S. Dist. LEXIS 232163 (W.D. La. Nov. 6, 2025).
Suggests Cautious Use of AI
Applies to AI Used for Filings/Drafting
E.D. La. – Judge Susie Morgan   10/3/2025 Generative AI  Generative AI Usage  In Lafontant v. Coolidge-CLK St. Germaine, LLC, 2025 U.S. Dist. LEXIS 196052 (E.D. La. Oct. 3, 2025), the defendants included citations with “non-existent” quotes and cases in their motion to strike the plaintiff’s opposition to their motion for partial summary judgment. During oral argument for a separate motion, the court questioned defendants’ counsel on the source of the citations in the motion to strike, and the attorney admitted that he did not review the final draft of the brief for accurate citations and that a law clerk and another lawyer were responsible for the draft and review. Unbeknownst to the attorney, the brief “was run to ChatGPT or [an]other Artificial Intelligence program” during the drafting process. Dkt. No. 52 at 4. Further, in response to the court’s order to show cause as to why sanctions would be inappropriate, counsel claimed to “immediately accept[] responsibility for the improper citations.” Judge Morgan ultimately found that defense counsel violated Rule 11 of the Federal Rules of Civil Procedure for failing to confirm the accuracy of their filing and falsely representing that cases cited in the motion to strike contained certain propositions. In consideration of the attorney’s “candor and sincerity,” the court (i) imposed a $1,000 personal fine; (ii) ordered defense counsel to attend 1 hour of a GenAI-focused CLE course; and (iii) referred defense counsel to the Disciplinary Committee of the Eastern District of Louisiana.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
E.D. La. – Judge Susie Morgan   8/28/2025  Generative AI Generative AI Usage  In Lee v. R&R Home Care, Inc., No. 2:24-cv-836, ECF No. 39 (E.D. La. Aug. 28, 2025), the plaintiffs’ opposition to the defendants’ motion to dismiss included a hallucinated case and falsely attributed quote. Counsel for the plaintiffs admitted to using Google Gemini to draft the opposition and failing to “verify the accuracy of the sources cited” during the hearing on the motion to dismiss and stated his awareness that GenAI tools were capable of producing hallucinated material. The court then ordered counsel for the plaintiffs to appear at a hearing on an order to show cause as to why sanctions should not be imposed, where he compared his conduct to cases in other jurisdictions where first-time offenders with one or few hallucinated citations were not sanctioned for expressing their remorse. Although the court considered the attorney’s “personal history, remorse, and subsequent efforts to educate himself on ethical AI use,” Judge Morgan ultimately imposed a $1,000 penalty, to be paid personally, and not by his law firm or the plaintiffs. 
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms
E.D. La. – Magistrate Judge Donna Phillips Currault 8/11/2025   Generative AI Suggests Cautious Use of AI In Herr v. Elos Env’t, LLC, 2025 U.S. Dist. LEXIS 155093 (E.D. La. Aug. 11, 2025), the pro se plaintiff included hallucinated citations in his reply brief in support of his motion to compel. The court recognized that the plaintiff may be unaware of GenAI’s ability to create fake cases, both given “the relative novelty of AI” and his pro se status. Magistrate Judge Currault declined to impose sanctions at this time but warned the pro se plaintiff that he could face sanctions if he were to include hallucinated authorities in future filings.
Applies to AI Used for Filings/Drafting
E.D. La. – Magistrate Judge Donna Phillips Currault  7/7/2025 Generative AI  Generative AI Usage In Tijerino v. Spotify USA Inc., 2025 U.S. Dist. LEXIS 127818 (E.D. La. July 7, 2025), as an exhibit to their memorandum in opposition to the pro se plaintiff’s motion to compel, the defendant attached an email thread between the parties where the defendant accused the plaintiff of using AI to “generate a formulaic and inaccurate letter” in preparation of the meet-and-confer and later using AI during the meet-and-confer to provide responses to the defendant’s question that were ultimately contradictory. See ECF No. 44-2 at 17. In fact, the defendant noted that use of the AI tool “made it difficult for [them] to understand [plaintiff’s] position because the position seemed to change based on how the AI program responded to [their] most recent statement.” Id. at 5. The court concluded that the plaintiff “did not confer in good faith” with the defendant as required by Rule 37 of the Federal Rules of Civil Procedure. The court described this failure as “sufficient reason in itself to deny the motion.” 
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Parties