| Court - Judge Name | Applicable To | Categories | ||
| N.D. Ga. – Judge Regina D. Cannon | 10/23/2025 | Generative AI | Generative AI Usage | In Quezaire v. Technipower Inc., 2025 U.S. Dist. LEXIS 208947 (N.D. Ga. Oct. 23, 2025), the pro se plaintiff submitted more than 400 discovery requests that the court presumed were drafted with a GenAI tool. The court issued an order to show cause, mandating that the plaintiff include an “AI-disclosure certificate” to “any paper filed with the Court.” The plaintiff did not include this certification in the next four filings submitted; rather, he submitted a statement appended to the second filing stating that he declines to include this AI-related certification, and submitting three filings containing 11 misrepresented or hallucinated citations (one of which was submitted after the court’s order to show cause). During the hearing on the order to show cause, the plaintiff claimed the court’s requirement was “vague” and lacked any definition of “AI” (arguing that search engines could constitute AI), and provided no explanation about his use of AI tools to draft the discovery requests. The defendant ultimately moved for sanctions given the pro se plaintiff’s non-compliance with Federal Rules of Civil Procedure 11 and 41(b) for submitting frivolous filings and failing to comply with a court order. The court granted the motion in part, finding that monetary penalties were inappropriate given the plaintiff’s in forma pauperis status, but deeming dismissal of the case without prejudice appropriate because the plaintiff’s misconduct was “persistent and willful.” Judge Cannon described the misconduct as “a microcosm of larger trends—misinformation and disrespect for the rule of law—that, when conspiring together, portend a frightful future.” |
| Court-Imposed Consequences – Parties | ||||
| E.D. Okla. – Magistrate Judge Jason A. Robertson | 10/22/2025 | Generative AI | Generative AI Usage | In Mattox v. Prod. Innovations Rsch., LLC, No. 6:24-cv-235-JAR, Dkt. No. 148 (E.D. Okla. Oct. 22, 2025), the plaintiffs submitted 11 filings with 14 hallucinated citations and quotations and erroneous legal propositions. During one of the scheduled hearings on the court’s order to show cause, the undersigning attorney for each of the 11 filings admitted to using ChatGPT “to make his writing more persuasive,” that the tool “changed his citations,” and that he did not perform a cite check before filing. Id. at 8. Though the court scheduled additional show cause hearings, plaintiffs’ counsel did not appear. Magistrate Judge Robertson applied a framework specific to AI-generated filings to ultimately determine that plaintiffs’ counsel should be sanctioned for violating Rule 11 of the Federal Rules of Civil Procedure: (i) “verification and inquiry”; (ii) “candor and correction”; and (iii) “accountability and supervision.” Id. at 9-10. First, the attorneys failed to review the filings before submission and failed to contain the required certification indicating that AI tools were used in drafting the brief. Id. at 10-11. Second, the attorneys waited until the show cause hearing to disclose the use of ChatGPT and made no efforts to correct the citations. Id. at 11. Third, the referring law firm and local counsel provided no supervision over the filing attorneys, and the referring law firm had no firm-wide policy governing responsible AI use in cases referred to outside counsel. Id. at 12. Moreover, the court imposed the following: (i) striking of all filings containing hallucinated or incorrect citations; (ii) ordering plaintiffs’ counsel to file “verified amended pleadings” wholly drafted by humans without any GenAI use and with the required Certification of Verification within 60 days of the order; (iii) requiring payment of $11,747.95 from each of the two law firms responsible to reimburse opposing counsel for attorneys’ fees and costs. Magistrate Judge Robertson found these sanctions appropriate for the “reaffirmation of professional honor” and reminded the parties that “[g]enerative tools may assist, but they can never replace the moral nerve that transforms thought into advocacy.” Order at 19-20. |
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| W.D. Okla. – Judge Timothy D. DeGiusti | 9/9/2025 | Generative AI | Generative AI Usage | In Robinson v. Oglala Sioux Tribe, 2025 U.S. Dist. LEXIS 175528 (W.D. Okla. Sept. 9, 2025), the pro se plaintiff filed various motions with citations to “non-existent and misrepresented legal authority.” Though it is permissible for parties to use GenAI in this Court, Judge DeGiusti found that the plaintiff violated Rule 11 of the Federal Rules of Civil Procedure for submitting filings with unsupported claims. This misuse of AI, compounded with other misconduct (e.g., filing excessive motions, notices, and supplements; and “fabricated evidence”), warranted sanctions in the form of dismissing the plaintiff’s claims with prejudice. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| DeKalb Cnty. Ct., Ga. – Judge Ana María Martinez | 8/28/2025 | Generative AI | Generative AI Usage | In Am. Express Nat’l Bank v. Moore, 2025 Ga. State LEXIS 5083 (Ga. Cnty. Ct. Aug. 28, 2025), the pro se defendant’s motion to vacate default judgment contained various hallucinated citations. As the court was sympathetic to the defendant’s inexperience, Judge Martinez declined to impose sanctions, but warned the defendant of the possibility of consequences in the future. In including false citations, the court noted that its “time is taken from other important endeavors,” resources are wasted, and judges and courts can face reputational harm for incorrectly being flagged as the author of the “bogus opinions.” The court ultimately denied the offending motion, and then also denied other related motions as moot. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Okla. -- Judge Bernard M. Jones | 5/23/2025 | Generative AI | Generative AI Usage | In Luther v. Oklahoma Dep’t of Hum. Servs., 2025 WL 1483695 (W.D. Okla. May 23, 2025), the court observed that the pro se plaintiff cited a case that “does not appear to exist” in her objection to a magistrate judge’s recommendation denying in forma pauperis status. The court expressed “serious reason to believe that Plaintiff used artificial intelligence tools to assist in drafting her objection,” noting that such tools “often cite[] to legal authorities . . . that do not exist.” While the court did not impose sanctions at this stage, it explicitly warned that “[c]ontinuing to cite to non-existent cases will result in sanctions up to and including dismissal.” |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Okla. – Judge Scott L. Palk | 7/3/2025 | Generative AI | Generative AI Usage | In Hill v. State of Oklahoma ex rel. Oklahoma Medical Marijuana Authority, 2025 WL 1840659 (W.D. Okla. July 3, 2025), the plaintiff’s counsel included “inaccurate, nonexistent” citations in their response to the defendant’s motion to dismiss. The court concluded that the citations were either generated by AI or the product of “exceptionally sloppy work.” The court declined to impose sanctions on plaintiff’s counsel but warned of the risk of sanctions should future briefings contain hallucinated citations. Judge Palk also emphasized that plaintiff’s counsel failed to follow Chambers Rules, which require parties to disclose whether any GenAI tool was used in drafting a filing and to verify that all cited authority is accurate. |
| Requires Disclosure and/or Verification | ||||
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| E.D. Okla. - Magistrate Judge Jason A. Robertson | 9/27/2023 | Generative AI | Generative AI Usage | This standing order applies to the use of generative AI for “preparation of any documents” and requires disclosure of “the specific AI tool” used, and certification that output drafted by gen AI tools was checked for accuracy. The title and primary portion of the order specify that the order applies only to “generative artificial intelligence.” The use of the phrase “preparation” (as opposed to “filing” or “drafting”) could indicate disclosure and verification are required when generative AI tools are used in any part of the preparatory process, including research. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Research | ||||
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Okla. - Judge Scott Palk | 9/6/2023 | Generative AI | Generative AI Usage | This standing order applies to the use of generative AI for “preparation of any documents” and requires disclosure of “the specific AI tool” used, and certification that output drafted by gen AI tools was checked for accuracy. The title and primary portion of the order specify that the order applies only to “generative artificial intelligence.” The use of the phrase “preparation” (as opposed to “filing” or “drafting”) could indicate disclosure and verification are required when generative AI tools are used in any part of the preparatory process, including research. |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Research | ||||
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Okla. - Bankruptcy | 9/1/2023 | Generative AI | Generative AI Usage | This general standing order is limited to filings drafted using generative AI and requires disclosure of the tool used and the portions of text the gen AI tool was used for, as well as certification both that the document was checked for accuracy and that the use of the gen AI tool did not disclose confidential information to any unauthorized party. The title and primary portion of the order specify that the order applies only to “generative artificial intelligence.” |
| Requires Disclosure and/or Verification | ||||
| Applies to AI Used for Filings/Drafting |


