Gauthier v. Goodyear Tire & Rubber Co.
U.S. District Court, Eastern District of Texas · E.D. Tex. · Texas bar guidance
Verified May 5, 2026
- Citation
- Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281 (MAC) (E.D. Tex. Nov. 25, 2024)
- Decided
- November 25, 2024
Summary
Plaintiff's counsel Brandon Monk used Anthropic's Claude to draft a response opposing summary judgment in a wrongful termination action, then filed it without independently verifying the output. The Response cited two nonexistent Fifth Circuit decisions (Roca v. King's Creek Plantation, LLC and Beets v. Texas Instruments, Inc.) and included fabricated quotations attributed to six additional real cases. Monk told Judge Marcia A. Crone at a show-cause hearing that he had attempted to validate the brief using a Lexis AI feature, which failed to flag the issues, and that he took no corrective action even after opposing counsel identified the problems in its reply. The court found violations of Rule 11(b)(2) and Eastern District of Texas Local Rule AT-3.
- AI tool:
- Claude
- Sanction amount:
- $2,000
What sanction did the court impose?
Judge Crone ordered Monk to pay a $2,000 penalty into the court registry, complete at least one hour of Texas MCLE credit on generative AI in the legal field by February 3, 2025, and provide a copy of the sanctions order to his client with docket certification within 21 days.
Why does Gauthier v. Goodyear Tire & Rubber Co. matter for law firms using AI?
Gauthier is the second documented sanctions order naming Anthropic’s Claude as the source of fabricated citations, and an early example of a court treating a vendor-marketed legal AI verification feature, here a Lexis AI tool, as no substitute for the attorney’s own duty to confirm authorities. Firms relying on layered AI workflows should note that the verification step the court demands is human, not algorithmic.
Sources
Primary sources
Further reading
- Legal news (secondary source)
- Justia (legal aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
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.