Cojom v. Roblen, LLC
U.S. District Court, District of Connecticut · D. Conn. · Connecticut bar guidance
Verified April 26, 2026
- Citation
- Cojom v. Roblen, LLC, No. 3:23-cv-1669 (JCH) (D. Conn. Nov. 17, 2025)
- Decided
- November 17, 2025
Summary
Plaintiff's counsel David P. Stich submitted a Memorandum in Opposition to Defendant's Motion to Set Aside Default containing multiple fabricated citations to legal authority generated by Descrybe.AI, a generative AI legal research tool. The court's Order to Show Cause identified three nonexistent cases purportedly from the District of Connecticut. Judge Janet C. Hall found Attorney Stich abdicated his Rule 11 duty to conduct a reasonable inquiry, noting the danger was heightened because his opponent was a defaulted pro se defendant unable to detect the phony citations.
- AI tool:
- Descrybe.AI
- Sanction amount:
- $500
What sanction did the court impose?
Judge Hall imposed a $500 monetary sanction under Rule 11. In mitigation, the court credited Attorney Stich's cancellation of his Descrybe.AI license, his commitment that neither he nor anyone in his employ would use AI in legal practice going forward, and his completion of CLE programming on AI in the legal profession. Attorney Stich was concurrently subject to a separate show-cause order before Judge Underhill in Davila v. Roblen, No. 3:23-cv-00512-SRU, involving the same AI tool.
Why does Cojom v. Roblen, LLC matter for law firms using AI?
Cojom illustrates the heightened risk profile when AI hallucinations slip into briefs filed against pro se opponents: with no adversary capable of catching fabricated citations, the burden falls entirely on the court, and the integrity cost is borne by a vulnerable counterparty. The order also documents a pattern, the same solo practitioner faced parallel show-cause proceedings before a second judge in the same district over briefs filed the same day using the same tool, a reminder that a single AI workflow lapse tends to surface across a practice rather than in isolation.
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.