City of Murfreesboro v. BFI Waste Systems of Tennessee, LLC
U.S. District Court, Middle District of Tennessee, Nashville Division · M.D. Tenn. · Tennessee bar guidance
Conduct
Plaintiff's counsel filed a brief with hallucinated quotations and misleading citations after failing to check content generated through AI tools.
Consequence
Here the court publicly reprimanded the drafting attorney and fined him $1,500, setting the sanction at the low end given his apology, remedial commitment and lack of known prior history.
Lesson
Here the court held the attorney who drafted the filing responsible, likening AI tools to junior staff whose work the supervising lawyer must verify.
Verified September 29, 2026
- Citation
- City of Murfreesboro v. BFI Waste Systems of Tennessee, LLC, No. 3:22-cv-00605, Memorandum Order (M.D. Tenn. Aug. 6, 2026) (Evans, M.J.), ECF No. 330
- Decided
- August 6, 2026
Summary
In the City of Murfreesboro's suit against BFI Waste Systems of Tennessee, LLC, on July 30, 2026, the court ordered several of the plaintiff's attorneys to show cause why they should not be sanctioned under Rule 11 or the court's inherent authority for filing a document (Doc. No. 293) that contained hallucinated quotations and misleading citations. Attorney Louis W. Ringger III responded on behalf of all of the attorneys. According to the order, Ringger "confirmed the Court's suspicion that a major factor in the deficiencies at Doc. No. 293--plus others that he identified (Doc. No. 328 at 6)--was the failure to check content generated through tools using artificial intelligence." He took responsibility as the document's sole drafter, apologized, described voluntary remedial steps to prevent a recurrence, asked that no sanctions be imposed, offered in the alternative to reimburse defense counsel's reasonable fees and costs for addressing the deficiencies, and submitted clean and redlined versions of a proposed corrected filing. The court found that he fell short "with quotations that did not exist and with legal citations that gave the impression that an argument in his favor had support when it did not."
- AI tool:
- Unnamed AI tools (counsel confirmed that a major factor was the failure to check content generated through tools using artificial intelligence)
- Sanction amount:
- Public reprimand and $1,500 payable to the Clerk of Court within 30 days (attorney Louis W. Ringger III)
What sanction did the court impose?
The court held that Ringger violated Rule 11 and must be sanctioned, while agreeing with him that sanctions under the court's inherent authority were not warranted. Weighing that he had no prior history of this conduct as far as the court knew, that he apologized, and that he committed to preventing a recurrence, the court set the sanction "at the low end" of the range it described from other cases. The order publicly reprimands Ringger and assesses a $1,500 monetary sanction payable to the Clerk within 30 days. Doc. No. 293 remains on the docket as filed, but Ringger was granted leave to file the proposed supplemental corrected response. Because no opposing party had moved for fees, the court noted that any monetary sanction would be payable to the court. The magistrate judge proceeded by non-dispositive order because the sanction does not dispose of any claim or defense and was not imposed after judgment.
Why does City of Murfreesboro v. BFI Waste Systems of Tennessee, LLC matter for law firms using AI?
The memorandum order is brief, but it states a clear theory of why AI changes the risk without changing the rule. Magistrate Judge Evans wrote that “[t]here is nothing inherently wrong with using legal research tools powered by artificial intelligence,” comparing them to the junior attorneys, paralegals and librarians on whom supervising lawyers have always relied, and that “artificial intelligence is nothing more than a new and technologically interesting way to violate Rule 11.”
The distinct danger, in the court’s view, is speed and the appearance of review: “Submitting false legal authority by conventional means requires either willfulness or a failure by multiple professionals involved in the preparation of a document,” while “artificial intelligence combines the illusion of thorough review and analysis with the temptations of speed and low cost.” The court concluded that “[a]ttorneys now have the power to violate Rule 11 in embarrassing ways within minutes,” and that signatories must be able to “account for every factual assertion and every legal argument that they file.”
The sanction reflects the mitigation Ringger offered: no prior history as far as the court knew, an apology, and remedial steps. The court set the $1,500 fine “at the low end” and paired it with a public reprimand, while declining to proceed under its inherent authority. Firms documenting compliance may wish to consider that although several attorneys received the show-cause order here, the sanction ran only against the attorney who took responsibility as the document’s sole drafter.
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 AI-assisted research the way a supervising attorney verifies a junior lawyer's work. The court compared AI tools to staff whose output the signing attorney remains responsible for.
- Document who drafted a filing when several attorneys are on it; here several attorneys received the show-cause order, and the sanction ran against the one who took responsibility as sole drafter.
- Consider offering a corrected filing with the show-cause response; the court granted leave to file the proposed supplemental corrected response.
- Review filings for hallucinated quotations, not only invented cases; the violation here was quotations that did not exist and misleading citations.