Aguilar v. The Crawford Group, Inc.
U.S. District Court, District of Massachusetts · D. Mass. · Massachusetts bar guidance
Conduct
Pro hac vice counsel filed a strike opposition and three dismissal oppositions with citation errors, including a fictitious citation and case; he admitted AI for the first.
Consequence
Here counsel's firm must pay the Enterprise Defendants' fees and costs for three categories of briefing, capped at $10,000; his pro hac vice admission was revoked.
Lesson
Here counsel's belief that his enterprise AI tool would not hallucinate did not avoid sanctions, and filing flawed briefs after notice indicated more than mere carelessness.
Verified September 28, 2026
- Citation
- Aguilar v. The Crawford Group, Inc., No. 1:25-cv-12395-AK, Memorandum and Order on Motion for Sanctions (D. Mass. Sept. 25, 2026) (Kelley, J.), ECF No. 155
- Decided
- September 25, 2026
Summary
In a suit brought by Rosario Aguilar on behalf of Maryori M. Conde and her estate against The Crawford Group, Inc., several insurers, and other defendants, plaintiff's pro hac vice counsel Blake Lindemann, a California-barred attorney, filed an opposition to a motion to strike in which roughly half of the citations contained an error, including a quotation attributed to a case with a fictitious Westlaw citation and a real First Circuit case cited six times for a proposition it does not state. Three of his four later oppositions to motions to dismiss also contained citation errors, including a case that, after a search of Westlaw, Lexis, and Bloomberg, the court said "does not appear to exist" (counsel later supplied Dorchester Mutual Insurance Co. v. Krusell as the intended authority) and quotations absent from the cited cases. The court recounts that Lindemann admitted using AI to draft the first opposition, believing the enterprise-level version of the AI software he used did not hallucinate cases, and that he attributed the errors in two later oppositions to influenza. He withdrew the first opposition without explanation, never submitted the "correct draft" he said he had meant to file, and at one point suggested sanctions against the moving defendants instead.
- AI tool:
- Unnamed AI software (the court recounts that counsel admitted using AI to draft the opposition to the motion to strike, believing the enterprise-level version he used did not hallucinate cases; the court found it irrelevant that he had not admitted using AI in the Enterprise and Travelers oppositions)
- Sanction amount:
- The Lindemann Law Firm to pay the Enterprise Defendants' reasonable fees and costs for (a) replying to the opposition to their motion to strike, (b) filing the sanctions motion and its reply, and (c) replying to the opposition to their motion to dismiss, not to exceed $10,000; pro hac vice admission of attorney Blake Lindemann revoked
What sanction did the court impose?
Judge Angel Kelley granted the Enterprise Defendants' motion for sanctions and imposed sanctions on the court's own initiative under Rule 11, not reaching inherent authority or 28 U.S.C. section 1927. The Lindemann Law Firm must pay the Enterprise Defendants' reasonable fees and costs for replying to the opposition to the motion to strike, filing the sanctions motion and its reply, and replying to the opposition to their motion to dismiss, not to exceed $10,000, with a joint notice on the agreed amount (or separate notices if they cannot agree) due by October 23, 2026. Lindemann's pro hac vice status was revoked. Because Lindemann said he alone was responsible for the offending filings, local counsel Austin Dana was not sanctioned, but he was reminded of his obligations to assist and supervise pro hac vice counsel.
Why does Aguilar v. The Crawford Group, Inc. matter for law firms using AI?
After an epigraph, Judge Kelley opened with a broad observation, that “our collective character is tested with the influx of Artificial Intelligence (‘AI’) in the legal field,” before turning to a record that the court described as “a pattern of neglecting to confirm the accuracy of his submissions.” The court treated the question of AI use as secondary: “It is irrelevant that Lindemann has not admitted to using AI in the Travelers and Enterprise Oppositions. There is no rule against the use of AI in researching and drafting legal papers, but it must be utilized responsibly.” For the later briefs, “whether AI was used or not, Lindemann did not confirm the truthfulness of his citations.”
Persistence and candor shaped the result. Lindemann kept filing briefs with false or misleading citations after the defendants raised the problem, which the court said “indicates that this is not an instance of mere carelessness.” He withdrew the first opposition without explanation, “obfuscated” for five months, and “never submitted the correct draft.” The court credited his voluntary CLE on the ethical use of AI but found that it did not “detract from the need to deter Lindemann and other attorneys from irresponsibly using AI without confirming their work.”
Here the monetary sanction runs against the firm rather than the lawyer personally and is capped at $10,000 of the Enterprise Defendants’ fees and costs, and the order also revokes counsel’s pro hac vice status in a pending case. Firms that appear through pro hac vice counsel may wish to consider how the sponsoring local lawyer will learn of, and respond to, a citation problem raised by the other side.
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 citations regardless of the AI product used; here the court recounts that counsel believed the enterprise-level version of his AI software did not hallucinate cases, and it imposed sanctions anyway.
- Document candor steps when withdrawing a flawed filing. The court faulted counsel for withdrawing the opposition with no explanation and for five months of obfuscation before first admitting careless conduct, as far as the court was aware, in April 2026.
- Review local-counsel responsibilities when sponsoring pro hac vice counsel. The court declined to sanction local counsel because lead counsel admitted sole responsibility, and still reminded him of his duty to ensure pro hac vice counsel abides by the local rules.