June 1, 2026 (in 3 days): New York: 22 NYCRR Part 161 takes effect, system-wide AI policy for all UCS courts

Daniel Gentry v. Calvin Thompson, et al.

U.S. District Court, Eastern District of Louisiana · E.D. La. · Louisiana bar guidance

Court sanction

Verified May 14, 2026

Citation
Gentry v. Thompson, No. 25-1260, 2026 WL 787563 (E.D. La. Mar. 20, 2026) (Barbier, J.)
Decided
March 20, 2026

Summary

Defendants' counsel filed a memorandum containing nine case citations, of which the second and third were nonexistent. The court noted unusual bullet-point formatting in the brief and concluded counsel had not read the cases cited. The court imposed a monetary sanction and a formal admonishment after finding counsel had relied on ChatGPT-generated authority without verification.

AI tool:
ChatGPT
Sanction amount:
$1,250
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

$1,250 monetary sanction and formal admonishment of counsel for filing a memorandum with fabricated case citations generated by ChatGPT.

Why does Daniel Gentry v. Calvin Thompson, et al. matter for law firms using AI?

Gentry v. Thompson is a useful illustration for managing partners because the sanction was small but the reputational mechanics were not: the court documented that counsel filed bullet-formatted citations they had never opened. A nine-citation brief with two fabrications shows that partial verification is not verification. Firms whose review workflows assume “most of the cites checked out” as a pass condition should treat this order as evidence that opposing counsel and the bench will read every citation, not a sample.

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.