Jason M. Hatfield, P.A. v. Pirani
U.S. District Court, Western District of Arkansas · W.D. Ark. · Arkansas bar guidance
Conduct
Filed two motions in limine drafted with AI that cited nonexistent cases and quotations; admitted the AI use at the pretrial conference.
Consequence
$1,000 Rule 11 fine, appearance conditions in W.D. Ark., and referral to the Arkansas Office of Professional Conduct. The $1.67M in the same order was a RICO fee award, not a sanction.
Lesson
Striking the filings did not end the matter: the court still fined counsel and conditioned future appearances.
Verified September 30, 2026
- Citation
- Jason M. Hatfield, P.A. v. Pirani, No. 5:22-CV-5110 (W.D. Ark. Dec. 3, 2025)
- Decided
- December 3, 2025
Summary
Tony Pirani, an attorney who was a defendant in this RICO and civil conspiracy action, electronically signed and filed two motions in limine (Docs. 397 and 398) that contained citations to nonexistent cases and quotations of nonexistent caselaw passages. At the July 11, 2025 pretrial conference he admitted using artificial intelligence to draft them. The court struck both motions on July 16, 2025 and issued an order to show cause on July 31, 2025.
- AI tool:
- Unspecified (Pirani admitted using artificial intelligence; the orders name no tool)
- Sanction amount:
- $1,000 fine to the Clerk of the Court
What sanction did the court impose?
Rule 11 sanction (Dec. 3, 2025 Opinion and Order, ECF 451): a $1,000 fine payable to the Clerk of the Court; no new appearances as counsel of record in the Western District of Arkansas until the fine is paid; for two years after payment, Pirani must associate counsel on all appearances in the district; and the order and related materials were forwarded to the Arkansas Judiciary's Office of Professional Conduct. The same order awarded the plaintiff $1,578,172.50 in attorney fees and $93,388.40 in costs as the prevailing party on its RICO claim under 18 U.S.C. 1964(c), after a jury verdict against Pirani. That award is not a sanction, and the court declined to order a separate Rule 11 fee payment because it was 'already encompassed within the lodestar calculation.'
Why does Jason M. Hatfield, P.A. v. Pirani matter for law firms using AI?
Hatfield v. Pirani is easy to misread. The December 3, 2025 order that sanctioned Pirani for the fabricated citations also awarded the plaintiff $1,578,172.50 in attorney fees and $93,388.40 in costs, but that award was not about AI. A jury had found Pirani liable under RICO and for Arkansas civil conspiracy, and RICO makes a reasonable attorney’s fee mandatory for a successful plaintiff (ECF 451 at 5-9).
The sanction for the citations is in Section III of the order. The court imposed a $1,000 fine, barred Pirani from entering new appearances in the Western District of Arkansas until he pays it, and required him to associate co-counsel on every appearance in the district for two years afterward (ECF 451 at 10-13). It declined to add a separate Rule 11 fee award because the fees “directly resulting from his violations” were “already encompassed within the lodestar calculation.”
The court also rejected the argument that striking the motions was punishment enough. The strike was not “a sufficiently severe sanction, nor even was it much of a sanction at all,” the court wrote, because it had not stopped Pirani from raising the same objections at trial.
For firms documenting AI governance, the case is a reminder to read the order rather than the headline figure attached to a case name. Here the order itself separates the merits fee award from the sanction.