| Court - Judge Name | Applicable To | Categories | ||
| S.D. Miss. – Judge Keith Starrett | 10/22/2025 | Generative AI | Generative AI Usage | In Univ. Mall, LLC v. Okorie, 2025 U.S. Dist. LEXIS 207867 (S.D. Miss. Oct. 22, 2025), the plaintiff moved for a pre-filing injunction and for contempt against the pro se defendant, claiming the defendant has “abused the court system.” In granting the plaintiff’s motions, the court noted, among other instances of misconduct, the presence of various hallucinated citations in the defendant’s briefings, and concluded that he likely employed used GenAI to draft pleadings due to “the speed at which he generates filings.” The defendant did not dispute the court’s assumption. The court also cited the various other instances in which the defendant was “admonished” or sanctioned for including hallucinated cases in his filings in other courts. The court sanctioned the defendant, enjoining him from filing any new cases in any district court within the Fifth Circuit, or any state court in Mississippi or Texas, without first obtaining leave of court from the Chief Judge (or their delegee) of the relevant court. The court also enjoined the defendant from filing a motion for leave to file relief until he has “purg[ed] himself of the contempt sanctions imposed” by both a bankruptcy court proceeding (Docket No. 19-50379-KMS) and the sanctions imposed by Judge Starrett. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| S.D. Miss. – Magistrate Judge Bradley W. Rath | 9/17/2025 | Generative AI | Generative AI Usage | In Hill v. Auto Club Family Insurance, 2025 U.S. Dist. LEXIS 182282 (S.D. Miss. Sept. 17, 2025), the court expressed “concern[] that what [the pro se plaintiff] has offered as legal authority [in her brief in support of her discovery motions] is the result of output from generative artificial intelligence (AI), which is known to fabricate case citations.” Although the court did not sanction the plaintiff, or conclusively determine that her brief was generated using GenAI, it warned that she is “on notice that submitting documents containing AI hallucinations is sanctionable conduct,” and that even if she had not used AI, “she must still comply with Federal Rule of Civil Procedure 11,” and citing to “fake legal opinions” wastes the court’s time and violates Rule 11. The court ultimately denied the pro se plaintiff’s discovery motions on other grounds. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| S.D. Miss. – Judge Henry T. Wingate | 8/1/2025 | Generative AI | Generative AI Usage | In Mississippi Association of Educators v. Board of Trustees of State Institutions of Higher Learning, No. 3:25-cv-00417-HTW-LGI (S.D. Miss.), the defendants filed an unopposed motion to clarify the court’s order granting the plaintiffs’ temporary restraining order, as the order (ECF No. 51) “identifies incorrect plaintiffs and defendants; recites allegations that do not appear in the operative complaint and/or are not supported by record evidence; identifies, as quoted excerpts, certain terms that do not appear in the language of H.B. 1193; and relies upon the purported declaration testimony of four individuals whose declarations do not appear in the record for this case.” ECF No. 54 at 1-2. Two days later, the court sent a notice of correction to counsel of record for both parties, acknowledging that the “original version of [the] Order contained clerical errors referencing improper parties and factual allegations.” After receiving the notice, the defendants moved to “restore the original erroneous order” and sought an explanation from the court for the factual and legal errors in the order. ECF No. 58. Judge Wingate ultimately denied the defendants’ motion, holding that the court is under no obligation to “preserve superseded orders containing clerical errors once corrected.” ECF No. 65 at 2. |
| N.D. Miss. -- Judge Michael P. Mills | 5/12/2025 |
Any AI | Any AI Usage | In Newbern v. Desoto Cnty. Sch. Dist., 2025 BL 161262 (N.D. Miss. May 12, 2025), the court dismissed the pro se plaintiff’s federal claims “partially as a sanction” because she supported them with “fabricated authorities.” The court suggested that these fictitious cases were not cited by mistake, but were the result of the plaintiff’s decision to “manufacture precedent out of whole cloth” when she could not find supportive case law for her claims. The court described plaintiff’s motion to reconsider as “underwhelming,” particularly because it failed to “take issue with the fact that certain cases she cited in . . . do not actually exist.” The plaintiff’s reliance on these cases as “key authorities” for her claims further convinced the court that such citations was not “an innocent mistake.” Despite expressing the view that plaintiff is an “abusive litigant,” the court indicated that it would allow discovery to proceed on her state law claims, considering the interests of the minor child she represented, although noted that the case is currently stayed pending the Fifth Circuit’s ruling on a pending interlocutory appeal. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| N.D. Miss -- Judge Michael P. Mills | 4/16/2025 |
Generative AI | Generative AI Usage | In Ferris v. Amazon.Com Servs., LLC, 2025 U.S. Dist. LEXIS 73784, the court sanctioned a pro se plaintiff for his citations to false authorities from the use of GenAI. The plaintiff first cited a non-existent case in his complaint, and then—after the defendant alerted the court about the issue—filed a motion containing an additional six fake cases. The court found that the plaintiff violated Rule 11 of the Federal Rules of Civil Procedure and ordered him to show cause as to why his case should not be dismissed. At the show cause hearing, the plaintiff admitted to using AI to draft the filings and then also read a GenAI-drafted statement. While the court decided against dismissing the case, it ordered the plaintiff to “pay the costs incurred by Defendant attributable to responding to [plaintiff’s] fabricated citations.” |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties |
Mississippi
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