Jacob Doe v. The University of North Carolina System, et al.

How did the court address the AI-related conduct?

The court discharged the order to show cause without imposing a sanction. It first expressed its "disappointment" that the published article "falls short of the Court's expectations": counsel were "less than fully forthcoming" about the scope of the errors, which ran through five briefs, and "unduly minimized" them. It rejected one attorney's statement that "[t]he cases I cited were correct, but the quotes were hallucinated," holding that "[a]n inquiry that does not involve verifying quotes is never reasonable under the circumstances," and found that one attorney's certification of compliance with the district's Standing Order on the Use of Artificial Intelligence "was not true." Noting counsel's "long history of exemplary conduct before this Court," it found that "their efforts and their expressions of repentance are made in good faith and as such are sufficient to discharge the Order to Show Cause."

Why does Jacob Doe v. The University of North Carolina System, et al. matter for law firms using AI?

Doe v. University of North Carolina System began with a sua sponte order to show cause. After dispositive-motion briefing, the court identified six categories of citation defects in the plaintiff’s filings, including two cases that did not appear to exist and quotations not found in the cited cases, and it said some “might constitute AI hallucinations.” It required every attorney involved in drafting or signing the briefs to appear.

According to the court’s later order, counsel admitted the errors at the November 19, 2025 hearing and attributed them in large part to misuse of AI software and a failure to verify its outputs, even though they had certified that every statement and citation had been verified. Counsel offered to write a state bar journal article about what went wrong, and the court refrained from discharging the show-cause order while the article was prepared.

On June 16, 2026, the court discharged the order without a sanction, but only after setting out why the article fell short. The court found that counsel were “less than fully forthcoming” about the scope of the errors, and it rejected the article’s framing that a case was “correct” when only its quotation was hallucinated: “An inquiry that does not involve verifying quotes is never reasonable under the circumstances.” It also found that one attorney’s certification under the district’s AI standing order, which bars AI in research except the AI embedded in Westlaw, Lexis, FastCase, and Bloomberg and requires every citation to be checked, “was not true.” The discharge rested on counsel’s history before the court and the court’s finding that their efforts and repentance were in good faith. Firms documenting compliance may wish to consider that, here, the court treated a certification under a local AI standing order as a factual statement it could test against the record.