Jane Doe, et al. v. Lincoln Consolidated Schools, et al.

What sanction did the court impose?

The court ordered Plaintiffs' counsel Delaporte Lynch, PLLC, not the plaintiffs themselves, to reimburse Defendants' counsel for the reasonable costs and fees associated with researching the hallucinated case and raising the issue in their brief. No fixed monetary amount was set in the order; the court left the fee award to be quantified. The order was issued alongside a partial summary-judgment ruling that dismissed Counts II and III with prejudice and dismissed the Individual Defendants, leaving only the Title IX claim against Lincoln Consolidated Schools.

Why does Jane Doe, et al. v. Lincoln Consolidated Schools, et al. matter for law firms using AI?

Doe v. Lincoln Consolidated Schools is notable because the sanction sits inside an ordinary summary-judgment opinion, not a separate show-cause order, and because the firm’s defense was not “the AI lied to us” but “we did not use AI at all, this is a citation we accidentally Frankensteined together.” Judge McMillion rejected that explanation on the textual evidence: the docket number and Westlaw cite the firm produced did not match any of the four cases counsel claimed they had been merging, and none of those four cases even discussed the Michigan constitutional provision the cite was offered to support. For a managing partner, the takeaway is that “it was a paralegal copy-paste error” reads, to a court, the same as “we used AI and didn’t check it” once the citation cannot be reconstructed from the record. Fee-shifting was placed on the firm, not the client.