Ford v. Troy City School District
U.S. District Court, Northern District of New York · N.D.N.Y. · New York bar guidance
Verified May 5, 2026
- Citation
- Ford v. Troy City School District, No. 1:25-cv-00364 (AMN/DJS) (N.D.N.Y. Mar. 4, 2026)
- Decided
- March 4, 2026
Summary
Plaintiff's counsel Jasper L. Mills, III, of Mills Law Group PLLC, filed a late response to a motion to dismiss in a Title VI action that cited purported Eighth Circuit and District of Kansas authority for which neither defense counsel nor the Court could locate any case. Judge Anne M. Nardacci granted the motion as to the Title VI claim, remanded the state law claims to Rensselaer County Supreme Court, and ordered Mills to show cause why he should not be sanctioned under Rule 11(b).
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to Show Cause issued March 4, 2026. Mills was ordered to file a written submission by March 20, 2026 addressing whether he used artificial intelligence in drafting the Response and what steps he took to confirm the existence and validity of the cited caselaw. No monetary sanction was imposed in this order.
Why does Ford v. Troy City School District matter for law firms using AI?
Ford illustrates the now-routine pathway from an unverifiable citation to a Rule 11 show cause order. The opposing brief flagged that counsel could not locate the cited Eighth Circuit and D. Kan. authorities, the court independently confirmed that absence, and the order expressly directed Mills to address whether AI was used in drafting. For managing partners, the lesson is that courts no longer wait for a confession before naming generative AI in the show cause itself, and the procedural footprint, including a missed deadline and a paralegal-blame explanation, becomes part of the published record.
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.