Enzor / Bennington DUI matter (Vt.)
Vermont Superior Court, Bennington Unit (Criminal Division) · Vt. Super. Ct. · Vermont bar guidance
Verified May 1, 2026
- Decided
- April 1, 2025
Summary
Rutland attorney Thomas Lamar Enzor used a generative AI tool to help draft a motion in a Bennington County DUI case. The motion cited real cases but the AI-generated quotations attributed to those cases were fabricated. Judge Jennifer Barrett identified five errors in the filing and allowed Enzor to file a supplemental motion to correct them. The matter received attention in Vermont legal-press coverage in early 2026 (VTDigger, March 2026; Valley News, March 2026). The defendant in the underlying DUI case is not named in available coverage; the docket number was not disclosed. Enzor stated to VTDigger that "AI is just not reliable."
- AI tool:
- AI (unspecified generative tool)
How did the court address the AI-related conduct?
No formal disciplinary sanction on Enzor has been reported, and the Vermont Professional Responsibility Board's public decisions list (latest entry December 17, 2025) includes no AI-related matter. Judge Barrett's relief was procedural: she identified the five errors at hearing and permitted Enzor to file a supplemental motion correcting the fabricated quotations. The Bennington DUI case may continue under ordinary court timelines; the AI-citation aspect of the matter is resolved without formal discipline. The matter occurred in spring 2025, after the Vermont Judiciary Committee on Artificial Intelligence and the Courts issued its First Annual Report (March 1, 2025), and the report does not mention it.
Why does Enzor / Bennington DUI matter (Vt.) matter for law firms using AI?
The Enzor / Bennington DUI matter is a Vermont trial-court AI-citation incident known from press reporting. It postdates the Vermont Judiciary Committee’s First Annual Report (March 1, 2025), which does not mention it. For Vermont firms, the practical signal is the absence of a reported sanction: the trial court allowed a supplemental motion to correct the fabricated quotations, and no Professional Responsibility Board decision on the matter has been published. The Vermont Supreme Court later found a Rule 11(b)(2) violation on similar facts in LaRoche v. Sterett (Nov. 13, 2025). That outcome reflects current Vermont practice but is not a defense for a firm whose verification process produced the same fabricated-quotation problem in a federal filing or in a state matter before a judge less procedurally lenient than Judge Barrett.
Sources
Primary sources
Further reading
- https://vtdigger.org/2026/03/01/vermont-has-few-guardrails-to-restrict-how-lawyers-use-ai/
- https://vnews.com/2026/03/10/ai-threat-judicial-integrity/
- Justia (legal aggregator)
- Exact hearing date for Judge Barrett's identification of the five fabricated quotations is not stated in available coverage; both VTDigger and Valley News describe the matter as occurring in 2025 (VTDigger phrases it as 'last spring,' read against the March 2026 publication date). Date field set to 2025-04-01 as a mid-spring approximation pending docket retrieval; this should be confirmed against the Bennington County criminal docket.
- Underlying DUI defendant's name and Bennington County docket number were not disclosed in available secondary sources. The Vermont Public Portal Smart Search supports attorney-name lookups but Vermont court rules limit remote retrieval of criminal case documents to courthouse public-access terminals (vtcourts.gov), so the docket cannot be confirmed remotely.
- The full transcript of Judge Barrett's identification of the five errors is not publicly available; the 'five errors' count is reported by VTDigger (Charlotte Oliver reporting), and the procedural disposition (supplemental motion permitted, no formal discipline) is corroborated by Valley News follow-up (Eric Francis byline, Mar. 10, 2026).
- No primary court order PDF or Vermont Judiciary opinion was located for this matter. VTDigger does not report whether it was referred to the Professional Responsibility Board, and no public PRB decision on it was located.