Brooks v. Lowe's Home Centers, LLC
U.S. District Court, Western District of Louisiana, Alexandria Division · W.D. La. · Louisiana bar guidance
Verified May 5, 2026
- Citation
- Brooks v. Lowe's Home Centers, LLC, No. 24-1063, 2026 WL 936341 (W.D. La. Apr. 7, 2026)
- Decided
- April 7, 2026
Summary
Plaintiff's counsel W. Paul Wilkins and Ross M. LeBlanc of Dudley DeBosier Injury Lawyers filed an omnibus motion in limine in a trip-and-fall case whose brief contained a string of fabricated or doctored quotations. Reviewing the motion, Judge Jerry Edwards, Jr. found that a rule statement about prior settlements citing Tompkins v. Cyr, 202 F.3d 770 (5th Cir. 2000), had no basis in that opinion: the cited page concerned sanctions, not evidence, and the parenthetical "consequential fact" quote did not appear anywhere in the case. The court then identified five additional misquotations drawn from Bankcard America, Gilliam v. Uni Holdings, Menges v. Cliffs Drilling, King v. Illinois Central R.R., and Lasha v. Olin Corp.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court ordered Wilkins and LeBlanc to show cause in writing within fourteen days why they should not be sanctioned under Fed. R. Civ. P. 11 for misquoting precedent. The underlying motion in limine was granted in part, denied in part, and deferred in part on the merits.
Why does Brooks v. Lowe's Home Centers, LLC matter for law firms using AI?
Brooks illustrates how easily fabricated quotations slip past a brief reviewer when the surrounding citation looks legitimate. Six different cases were cited accurately by name and reporter, yet the language attributed to each was either invented or altered just enough to fit the proposition counsel wanted to advance. For a managing partner, the operative lesson is that citation-checking software that only verifies whether a case exists will not catch this failure mode; verification must extend to the quoted text and the pincite.
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.
- The order does not name a specific AI tool. The hallucination pattern (multiple fabricated verbatim quotes attached to real citations, with subtle word substitutions such as "policy" for "purpose" and "tortfeasor" for "defendant") is characteristic of large language model output, and the court itself observed that "[w]hether by humans or by large language models, misquoting precedent has never been okay." AI use is implied but not adjudicated.