Adams v. Matrix Providers Inc.
U.S. District Court, District of Colorado · D. Colo. · Colorado bar guidance
Conduct
Counsel's briefing cited a nonexistent case and misstated holdings; she said it was included inadvertently while a colleague and her paralegal helped finish the brief in a family emergency.
Consequence
Here the court admonished counsel over the citations; a separate $1,000 sanction in the same order was for courthouse photography and practice-standard violations.
Lesson
Here delegating final brief work to an unnamed colleague during an emergency did not excuse an unverified citation; the court expected every authority to be checked.
Verified September 29, 2026
- Citation
- Adams v. Matrix Providers Inc., No. 1:23-cv-01996-CNS-KAS, Order (D. Colo. Aug. 27, 2026) (Sweeney, J.), ECF No. 134
- Decided
- August 27, 2026
Summary
Audiologist Michele Adams sued Matrix Providers Inc. and Logistics Health Incorporated over her termination after she sought a religious exemption from a COVID-19 vaccination requirement. At the June 25, 2026 summary judgment hearing, at which the court granted both defendants' motions, Judge Charlotte N. Sweeney raised concerns about plaintiff's briefing, including "at least one phantom citation to a non-existent case, numerous instances of inaccurate citations of case holdings, and countless examples of Plaintiff failing to provide accurate record and evidentiary citations." The nonexistent case was "Ricks v. Starbucks." The court later received screenshots of an Instagram account it believed belonged to plaintiff's counsel, Nicole C. Pearson, including a photo of the case briefs captioned "Grifting is FUN!" and a photo taken in the hallway outside the courtroom in violation of Local Rule 83.1, and ordered her to show cause. In her response, Pearson said the Ricks citation was included inadvertently while she was handling a family emergency with help from an unnamed "colleague" and her paralegal, and that the case and quoted language exist but are not part of the same case.
- AI tool:
- Unidentified (the court states it is "unclear" whether the misstatements resulted from "the use of an AI legal search, or simply poor and unexacting legal judgment")
What did the court warn about?
The court denied the plaintiff's Rule 59(e) motion and her motion for leave to file late objections to the bills of costs. On the nonexistent citation, the court, "[w]hile doubting the likelihood of this explanation," elected to admonish Pearson, and reminded her that Ricks was "far from the only" questionable choice in the briefing, citing misstated holdings. It said whether those misstatements resulted from "the use of an AI legal search, or simply poor and unexacting legal judgment, is unclear," and that it "hopes that this incident serves as a warning" to her. Separately, the court accepted her explanation of the "Grifting" post but found she violated Local Rule 83.1 by photographing the courthouse hallway and repeatedly disregarded the court's practice standards (including filing two replies on each motion, exceeding the ten-page reply limit). For those procedural violations it sanctioned Pearson $1,000 under Rule 11(c)(1), Local Rule 83.1(e) and CNS Civil Practice Standard 1.1(c), payable to the court registry by September 18, 2026 and borne by her, not her client.
Why does Adams v. Matrix Providers Inc. matter for law firms using AI?
Adams is best read as an admonition on the citation issue inside a broader order on counsel’s compliance with court rules. Pearson said the “Ricks v. Starbucks” citation was an inadvertent error made while a colleague and her paralegal helped finish the brief during a family emergency. Judge Sweeney, while “doubting the likelihood of this explanation,” elected to admonish her. The court then pushed back on her suggestion that Ricks was the only suspect authority, pointing to misstated holdings; the court recounted counsel for Matrix explaining that essentially two citations per page were “wholly inaccurate” or not standing “for the points that Ms. Pearson asserted.”
The court declined to decide whether AI was involved. It wrote that “[r]egardless of whether and to what extent Ms. Pearson or her colleague did (or did not) use AI,” her briefing methods “wasted the time of the Court and opposing counsel,” and it quoted the Tenth Circuit’s observation in Amarsingh v. Frontier Airlines that “careless use of the tool can waste both judicial resources and the opposing party’s time and money.” The admonition is framed as a warning to exercise better judgment “regardless of whether she intends to continue using AI tools in the future.”
The monetary sanction in the same order rests elsewhere: photography in a public area of the courthouse in violation of Local Rule 83.1 and repeated disregard of the judge’s practice standards. Firms documenting compliance may wish to consider that this order treats the citation problem and the procedural violations separately, and that the fake citation drew an admonition rather than the fine.
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 cited authority when drafting help is brought in under time pressure. Here the court assumed counsel would not again delegate work to an unnamed colleague without verifying each citation.
- Review misstated holdings as well as nonexistent cases; the court stressed that Ricks was far from the only problem in the briefing.
- Document compliance with the assigned judge's practice standards and local rules; the monetary sanction in this order rested on those violations.
- Consider that a lawyer's social media posts about a case can prompt a show-cause order, as the Instagram screenshots did here.
Sources
Primary sources
- AI attribution is not a court finding. The order quotes counsel's own reference to Ricks as a case the court and Matrix "believe is fake and potentially AI-generated" and says it is "unclear" whether the other misstatements resulted from "the use of an AI legal search"; the tracker's AI classification is an inference.