Bevins v. Colgate-Palmolive Co.
U.S. District Court, Eastern District of Pennsylvania · E.D. Pa. · Pennsylvania bar guidance
Verified April 26, 2026
- Citation
- Bevins v. Colgate-Palmolive Co., No. 25-576 (E.D. Pa. Apr. 10, 2025) (Baylson, J.)
- Decided
- April 10, 2025
Summary
Attorney Nicholas L. Palazzo of DeFino Law Associates PC filed two opposition briefs containing fabricated citations: a purported "Tinch v. Video Indus. Servs., Inc., No. 1712 EDA 2018, 2019 WL 1396975 (Pa. Super. Ct. Mar. 27, 2019)" whose Westlaw number actually maps to Dolberry v. Jakob (N.D.N.Y. 2019) and whose docket number points to an unrelated criminal appeal, and a purported "Burton v. Danek, No. 95-5560, 1997 WL 436713 (E.D. Pa. July 31, 1997)" whose Westlaw number maps to Top Choice Distributors v. U.S. Postal Service (W.D.N.Y. 1997). Judge Michael M. Baylson concluded both citations were AI hallucinations stitched together from parts of real cases. Palazzo responded to the show-cause order with a memorandum blaming "tired" proofreading but did not submit the affidavit or annexed opinions the court had ordered, and was silent on the court's standing order on AI.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Sanctions issued under Fed. R. Civ. P. 11(b)(2) and 11(c)(3) were nonmonetary but severe: Palazzo's appearance in the case was stricken with prejudice, the Clerk was ordered to serve the sanctions memorandum on the State Bar of Pennsylvania and the E.D. Pa. Bar (both of which Palazzo is a member of), and Palazzo was ordered to inform his client that she must retain new counsel if she chooses to refile. The complaint was dismissed without prejudice with leave to amend within 30 days.
Why does Bevins v. Colgate-Palmolive Co. matter for law firms using AI?
Bevins shows how a single AI-generated citation can compound into a career-impacting sanction for the attorney even without a monetary fine. Judge Baylson tied the severity not just to Rule 11 but to noncompliance with his standing order on AI, which required counsel to certify that AI-assisted research had been verified. For managing partners, the operational lesson is that judge-specific AI standing orders are now a docket-level compliance surface: a firm needs a workflow that flags the assigned judge’s AI order before a brief is filed, not after a show-cause order issues.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.