Kenisha Black v. Mississippi Dept. of Rehabilitation Services & Howard
U.S. District Court, Southern District of Mississippi · S.D. Miss. · Mississippi bar guidance
Verified April 26, 2026
- Citation
- Kenisha Black v. Mississippi Dep't of Rehabilitation Servs. & Howard (S.D. Miss. Sept. 24, 2025)
- Decided
- September 24, 2025
Summary
Briefing in this matter contained citations and authorities that did not correspond to the cases as represented, indicative of generative AI hallucinations introduced during drafting. After the issue was raised, counsel submitted corrected briefs replacing the defective citations, and the court accepted the corrected filings in lieu of imposing monetary sanctions or striking the underlying motions. The specific AI product used was not identified on the record.
- AI tool:
- Unidentified generative AI tool
- Sanction amount:
- None
What sanction did the court impose?
Court accepted corrected briefs in place of the originals containing hallucinated authorities. No monetary sanction or formal disciplinary referral was imposed in the order.
Why does Kenisha Black v. Mississippi Dept. of Rehabilitation Services & Howard matter for law firms using AI?
Black is an example of the lighter end of the AI-hallucination response spectrum: the court permitted counsel to cure defective AI-generated citations by substituting corrected briefs, rather than imposing Rule 11 sanctions, fee-shifting, or disciplinary referral. For firms documenting compliance posture, this case illustrates that judicial tolerance for a first-time, promptly-corrected hallucination still exists in some districts, but it is not a strategy: the same conduct in front of a different judge in the same district could yield a published sanctions order. The defensive posture is unchanged, verify every cited authority against the primary source before filing, regardless of which tool produced the draft.
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.
- Civil action number not extracted (source PDF returned as binary-encoded by available fetch tools and could not be parsed for the docket number).
- Identity of the presiding judge not confirmed from the order text.
- Identity of the specific generative AI tool used by counsel not stated in available materials.
- Whether the corrected-brief disposition included any admonishment, CLE requirement, or referral language not confirmed without parsed PDF text.