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)
What sanction did the court impose?
No formal disciplinary sanction was imposed on Enzor, and the matter was not publicly referred to the Vermont Professional Responsibility Board. 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 case is documented here because Vermont's Judiciary Committee on Artificial Intelligence and the Courts cited the absence of formal discipline as informing its recommendation not to amend the Vermont Rules of Professional Conduct.
Why does Enzor / Bennington DUI matter (Vt.) matter for law firms using AI?
The Enzor / Bennington DUI matter is the highest-profile Vermont AI-citation incident on public record and is cited in the Vermont Judiciary Committee’s First Annual Report (March 2025) as part of the empirical basis for the Disciplinary Rules Subcommittee’s recommendation against amending the Vermont Rules of Professional Conduct. For Vermont firms, the practical signal is the absence of a sanction: the trial court treated the AI-citation issue as a Rule 11-style correction matter rather than a Rule 3.3 candor matter, and the Professional Responsibility Board did not pursue discipline. 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 (Brendan Lalor 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 exists for this matter; absence of a Professional Responsibility Board referral is itself the news, and is reported as such.