Raul Gonzales Davila v. Roblen, LLC f/d/b/a Vicolo Pizza Restaurant
U.S. District Court, District of Connecticut · D. Conn. · Connecticut bar guidance
Verified April 26, 2026
- Citation
- Davila v. Roblen, LLC, No. 3:23-cv-00512 (SRU), 2026 WL 323134 (D. Conn. Feb. 6, 2026) (Underhill, J.)
- Decided
- February 6, 2026
Summary
Plaintiff's counsel David Stich filed a memorandum of law in opposition to summary judgment that contained multiple AI-generated quotes attributed to real cases that did not contain those quotes. Most notably, the brief cited Pineda v. Frisolino, Inc., 2017 WL 3835882 (S.D.N.Y. Aug. 29, 2017), a real FLSA decision, but quoted it as stating "any regular contact with goods that have moved in interstate commerce is sufficient," language that does not appear in the opinion. Judge Stefan R. Underhill found Stich had negligently failed his duty as an officer of the court by basing client arguments on fake law without conducting a reasonable inquiry. Co-counsel Stephanie Stich (David Stich's daughter) had separately phoned chambers to request leave to file a "corrected version" without disclosing the hallucinations; the court declined to sanction her. David Stich had previously been sanctioned $500 by Judge Janet C. Hall in the parallel Cojom v. Roblen matter for similar AI-generated citations to non-existent cases.
- AI tool:
- Unspecified generative AI research tool
What sanction did the court impose?
No monetary sanction. David Stich ordered to (a) complete at least three hours of CLE on the responsible use of AI in legal practice, and (b) share his new knowledge with the Connecticut legal community in written form (e.g., a blog post, op-ed, or letter to the editor). No sanctions imposed on Stephanie Stich.
Why does Raul Gonzales Davila v. Roblen, LLC f/d/b/a Vicolo Pizza Restaurant matter for law firms using AI?
Davila is the second sanctions order against the same attorney in the District of Connecticut for AI-generated fake quotations, following Judge Hall’s $500 sanction three months earlier in the parallel Cojom v. Roblen matter. For a managing partner, the case underscores two things: first, that “fake quote pinned to a real case” is the harder hallucination to spot, since cite-checkers often confirm the case exists and stop there; second, that a court will weigh prior AI-related discipline when calibrating the sanction, and Judge Underhill’s CLE-and-publication remedy here reads as a final warning before the next escalation.
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.