Dodge v. FirstService Residential Arizona LLC
U.S. District Court, District of Arizona · D. Ariz. · Arizona bar guidance
Verified May 5, 2026
- Citation
- Dodge v. FirstService Residential Arizona LLC, No. 2:24-cv-01550-PHX-SMM (D. Ariz. Dec. 8, 2025)
- Decided
- December 8, 2025
Summary
Plaintiff's counsel Matthew V. Moosbrugger filed briefing containing fabricated case citations generated by an AI tool, including at least one citation to a case the court determined did not exist and a quoted proposition that did not appear in the cited authority. After the court issued an Order to Show Cause on November 6, 2025 under Federal Rule of Civil Procedure 11, Moosbrugger appeared at a hearing on November 21, 2025 before the District of Arizona.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. The court found that the public humiliation associated with the matter, combined with Moosbrugger's loss of any contingency fee following dismissal, was a sufficient remedy. The court directed the Clerk to forward a copy of the order to the State Bar of Arizona Disciplinary Committee and encouraged Moosbrugger to attend continuing legal education on the appropriate use of AI.
Why does Dodge v. FirstService Residential Arizona LLC matter for law firms using AI?
For a managing partner, Dodge illustrates that a court can decline to impose a monetary penalty and still inflict the sanction that matters most for a small firm: a referral to state bar discipline and a published order naming the lawyer. The firm absorbs the reputational hit and the bar inquiry regardless of the dollar figure on the docket.
Sources
Primary sources
Further reading
- https://app.midpage.ai/document/dodge-v-firstservice-residential-arizona-1000462312637
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
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.
- Specific name of the AI tool used by counsel. The Charlotin index lists 'Federally Lawyer,' which appears to be a mangled or OCR'd label; the underlying PDF text could not be extracted from the hosted copy and the secondary source (Midpage) was rate-limited at the time of verification. Recorded as 'Unspecified generative AI' pending direct read of the order.