Gardner v. Combs
U.S. District Court, District of New Jersey · D.N.J. · New Jersey bar guidance
Verified May 5, 2026
- Citation
- Gardner v. Combs, No. 2:24-cv-07729-LMG-JRA, ECF No. 92 (D.N.J. Dec. 15, 2025)
- Decided
- December 15, 2025
Summary
Plaintiff's counsel Tyrone A. Blackburn of T. A. Blackburn Law, PLLC, repeatedly cited a non-existent case, "United States v. Masha, 990 F.3d 1005, 1014 (7th Cir. 2021)," and other fabricated legal propositions generated by AI in his opposition to motions to dismiss. Judge Leo M. Gordon (U.S. Court of International Trade, sitting by designation) found that Blackburn admitted using AI that produced hallucinated authority and failed to verify the citations even after defense counsel flagged the Masha citation in a reply brief. The court imposed a sanction at the higher end of the comparable range, citing pattern conduct, including a prior Rule 11 sanction for similar AI-related citation errors in Jakes v. Youngblood (W.D. Pa.).
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $6,000
What sanction did the court impose?
$6,000 Rule 11(c) monetary sanction payable to the court registry at $500/month from March 2026 through February 2027; required self-report to attorney licensing authorities in New Jersey and New York; required service of the order, OSC, and related materials on the client with a discussion of their implications; written compliance report due to the court.
Why does Gardner v. Combs matter for law firms using AI?
Gardner v. Combs is notable for the court’s express reliance on the attorney’s pattern of conduct: Blackburn had been sanctioned weeks earlier in the Western District of Pennsylvania for similar AI-related errors and had publicly represented that he had re-engineered his practice with new verification protocols. The order shows that prior AI-sanctions discipline, far from insulating an attorney, becomes an aggravating factor when a second hallucinated citation surfaces. For managing partners, the case illustrates why a documented firm-wide AI verification policy, applied uniformly, is more defensible than reliance on individual attorney remediation after a first incident.
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.