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Kenisha Black v. Mississippi Department of Rehabilitation Services & Howard

U.S. District Court, Southern District of Mississippi · S.D. Miss. · Mississippi bar guidance

Other

Verified September 29, 2026

Citation
Black v. Mississippi Department of Rehabilitation Services, Civil No. 3:23-CV-426-DPJ-ASH, ECF No. 56 (S.D. Miss. Sept. 24, 2025) (Jordan, J.)
Decided
September 24, 2025

Summary

After losing on summary judgment, plaintiff Kenisha Black moved for reconsideration. Her counsel later moved for leave to substitute corrected memoranda, and the court records that "Plaintiff's counsel admits that her opening memorandum and reply brief both contained false AI-generated content." Judge Daniel P. Jordan III wrote that "Plaintiff's initial briefs supporting reconsideration violated Rule 11, so Black's counsel did the right thing by self-reporting," but noted in a footnote that Defendants had signaled incorrect authority in February 2025 and that "Plaintiff did the same thing in reply and then waited seven months to file a motion to correct the briefing," citing a show-cause order in Lewis v. Entergy Miss., LLC "raising use of AI-generated case citations by Plaintiff's counsel."

AI tool:
Not identified (counsel "admits that her opening memorandum and reply brief both contained false AI-generated content")
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

How did the court address the AI-related conduct?

No sanction was imposed. The court denied the motion for leave as moot, noting "that the corrected briefs remain in the record," declined to require further briefing from Defendants so they would not incur additional expense, and denied the motion for reconsideration on the merits.

Why does Kenisha Black v. Mississippi Department of Rehabilitation Services & Howard matter for law firms using AI?

Black shows a court finding a Rule 11 violation, crediting counsel’s self-report, and imposing no sanction. The order credits the self-report (“Black’s counsel did the right thing by self-reporting”) but also notes that opposing counsel had flagged incorrect authority months earlier and that counsel “did the same thing in reply and then waited seven months to file a motion to correct the briefing.” The court avoided further briefing so Defendants would not incur more expense. Firms may wish to note that the timing of a correction, not only its existence, featured in the court’s account.

Sources

Primary sources