Jacob Doe v. The University of North Carolina System, et al.
U.S. District Court, Western District of North Carolina, Asheville Division · W.D.N.C. · North Carolina bar guidance
Verified May 14, 2026
- Citation
- Doe v. Univ. of N.C. Sys., No. 1:23-cv-00041-MR (W.D.N.C. Nov. 10, 2025) (order to show cause)
- Decided
- November 10, 2025
Summary
Chief Judge Martin Reidinger issued a sua sponte order to show cause directing plaintiff's counsel to appear and explain why they should not be sanctioned under Federal Rule of Civil Procedure 11(c)(3). Reviewing the parties' dispositive-motion briefing, the Court identified six categories of defective citations in the plaintiff's filings, including two cases that do not appear to exist, fabricated quotations attributed to cited cases, mischaracterized holdings, irrelevant cites, missing pinpoint and court-of-origin information, and an out-of-circuit case misidentified as Fourth Circuit authority.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause set for hearing on November 19, 2025. The Court ordered every attorney who drafted, prepared, or signed the plaintiff's briefs at Docs. 114, 116, 139, 141, 144, 146, and 156 to appear in person. No monetary sanction had been imposed as of the order date; the show-cause hearing will determine whether sanctions issue.
Why does Jacob Doe v. The University of North Carolina System, et al. matter for law firms using AI?
Doe v. UNC illustrates how Rule 11 enforcement is moving upstream: a chief judge reviewing summary-judgment briefing on his own initiative, cataloguing six discrete citation defects, and compelling every signatory and drafting attorney to appear in person. For managing partners, the lesson is that AI-assisted briefing failures are increasingly being detected by the court rather than opposing counsel, and that supervisory attorneys who merely signed the brief are pulled into the show-cause hearing alongside the drafter.
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.