Adams v. 3M Company
U.S. District Court, Northern District of Alabama, Middle Division · N.D. Ala. · Alabama bar guidance
Conduct
Here plaintiffs' counsel filed an opposition brief with nonexistent citations, misread holdings and false quotes that she later said came from AI-assisted research tools.
Consequence
Rule 11(b)(2) violation found; public reprimand and no further sanction, with a warning that future AI misuse before any judge in the district will likely bring severe sanctions.
Lesson
Here a candid admission and a written corrective plan after a show-cause order led the court to stop at a public reprimand, though it called the number of errors egregious.
Verified September 30, 2026
- Citation
- Adams v. 3M Co., No. 4:24-cv-832-CLM, Order (N.D. Ala. May 26, 2026) (Maze, J.), ECF No. 45; Show Cause Order (N.D. Ala. Apr. 20, 2026), ECF No. 43
- Decided
- May 26, 2026
Summary
Bridgett Watson Adams and other plaintiffs sued 3M Company in a removed diversity action. After granting 3M's Rule 12(c) motion for judgment on the pleadings with leave to amend, Judge Corey L. Maze entered a show-cause order on April 20, 2026. It noticed that plaintiffs' opposition brief "was riddled with misquotes, false quotes, strained case interpretations, and citations that seem to have been outright fabricated," and charted nine errors. Among them: "Adams v. 3M Co., 67 F.4th 845" led to an unrelated Sixth Circuit trademark case; the real Adams v. 3M Co. involved respirators, not PFAS; a "Jarrod Johnson" citation led to a Tenth Circuit criminal case; Payton v. Monsanto was cited for a discovery rule the Alabama Supreme Court rejected; Southern Bakeries v. Knipp was described as a "union boycott" case; and quotations attributed to Gonsalvez, Ex parte Abbott Laboratories, Ex parte McKesson, and Moon v. Harco Drugs did not match the opinions. The court asked counsel to explain whether she "personally make up" the two citations or "use an AI platform that made them up." Plaintiffs' counsel Dagney Johnson responded on April 30, 2026.
- AI tool:
- Generative AI (per the court, counsel admitted using generative AI; her response attributes the errors to "AI-assisted research and summary tools"; no tool is named)
- Sanction amount:
- Public reprimand only (no monetary sanction), with a warning that future misuse of AI before any judge in the district "will likely result in severe sanctions"
What sanction did the court impose?
On May 26, 2026, the court found that the fake cases, misstatements of law, and inaccurate quotes violated Rule 11(b)(2), and that the number of inaccurate citations and quotations "was egregious." It recounted that Johnson admitted using generative AI, took full responsibility, candidly explained the errors, apologized to defense counsel, and listed corrective actions she planned to take. Because her "candid response and voluntary corrective action distinguishes her from other attorneys' reactions to similar AI-related show cause orders entered by my colleagues," the court found "that it needn't impose a sanction beyond this public reprimand." It warned Johnson "that future misuse of artificial intelligence before any of the judges in this district will likely result in severe sanctions," and said a separate order would set a schedule for the amended complaint.
Why does Adams v. 3M Company matter for law firms using AI?
The Adams show-cause order is a detailed audit of one brief. Judge Maze wrote that “both the court and its clerks have spent far too many hours charting these errors and trying to determine their origin,” and sorted them into hallucinated citations, “real cases, wrongly read,” and “quotes that aren’t quotes.” The court was careful about attribution at the show-cause stage. It said that “someone—either Plaintiffs’ counsel or an AI platform—hallucinated” the Adams parenthetical, and it framed the question for counsel directly: did she make up the citations, or “did she use an AI platform that made them up?” It added: “Both scenarios are sanctionable, but the repercussions differ.”
Counsel’s response was one reason for the outcome. In her filed response, she attributed the errors to “reliance during the drafting process on AI-assisted research and summary tools,” a failure to verify each citation and quotation, and “an inadvertent inclusion of written sections that had been previously stricken during the revisions of the brief,” and she listed corrective measures. The May 26 order found a Rule 11(b)(2) violation and called the number of errors “egregious,” but concluded that the show-cause order itself was “sufficient to convey the seriousness of this matter,” and stopped at a public reprimand.
The court contrasted this response with “other attorneys’ reactions to similar AI-related show cause orders entered by my colleagues,” without naming those cases. Firms documenting compliance may wish to consider that, here, the court tied the lighter result expressly to candor and voluntary corrective action, while warning that “future misuse of artificial intelligence before any of the judges in this district will likely result in severe sanctions.”
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify every citation, parenthetical and quotation against the source opinion before filing. Here the court charted nine errors and found the brief violated Rule 11(b)(2).
- Document the firm's response to a show-cause order. Here the court credited counsel's admission, explanation, apology to opposing counsel and list of corrective actions in declining a sanction beyond the reprimand.
- Review final assembly of briefs. Counsel's response said citations stricken from early drafts reappeared in the filed version; the court's order did not address that explanation.
- Consider that a warning can reach beyond one judge. Here the court warned counsel about future misuse before any of the judges in the district.