Davis v. Marion County Superior Court Juvenile Detention Center
U.S. District Court, Southern District of Indiana, Indianapolis Division · S.D. Ind. · Indiana bar guidance
Verified May 5, 2026
- Citation
- Davis v. Marion Cnty. Superior Ct. Juvenile Det. Ctr., No. 1:24-cv-01918-JRS-MJD, 2025 WL 2502308 (S.D. Ind. Sept. 2, 2025)
- Decided
- September 2, 2025
Summary
Plaintiff's counsel Tae Sture filed a response to a motion to compel containing two fabricated case citations, including a quote attributed to "Perry v. City of Indianapolis, 2019 WL 2088435," which Magistrate Judge Mark J. Dinsmore found was "a rather bizarre amalgamation of several cases." Sture acknowledged he had a paralegal draft the brief on a short deadline and did not review the citations before filing. The paralegal denied using generative AI and claimed she used Fastcase, but neither offered any alternative explanation for the fabrications.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $7,500
What sanction did the court impose?
Magistrate Judge Dinsmore recommended a $7,500 Rule 11 sanction against Sture personally, referred the matter to the Chief Judge under Local Rule of Disciplinary Enforcement 2(a) for consideration of further discipline, and ordered Sture to provide a copy of the order to his client and file a certification within seven days. The recommendation expressly noted that prior modest sanctions ($2,000 to $6,000 in similar cases including Mata v. Avianca) had failed to deter the conduct.
Why does Davis v. Marion County Superior Court Juvenile Detention Center matter for law firms using AI?
Davis is notable for two reasons relevant to firm leadership. First, it is an explicit judicial signal that the prevailing $2,000 to $6,000 sanction range, anchored by Mata v. Avianca, is being escalated because it has not deterred repeat conduct; the court collected eleven additional fictitious-citation cases from a single month (August 2025) to support the increase. Second, the order treats supervision failure as the operative breach: counsel’s “abdication of his responsibility to ensure that the information he provided to the Court was accurate” was sanctionable regardless of whether the paralegal actually used generative AI, and good faith was no defense.
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.