Latasha Hill v. Auto Club Family Insurance Company
U.S. District Court, Southern District of Mississippi · S.D. Miss. · Mississippi bar guidance
Verified May 14, 2026
- Citation
- Hill v. Auto Club Family Ins. Co., No. 2:24-cv-00107-KS-BWR, 2025 WL 2663676 (S.D. Miss. Sept. 17, 2025) (Rath, M.J.)
- Decided
- September 17, 2025
Summary
Latasha Hill, proceeding pro se after her counsel withdrew, filed seven late discovery motions in her wind-damage insurance suit against Auto Club Family Insurance Company. Magistrate Judge Bradley Rath denied all seven as untimely and procedurally improper. In the course of the good-faith analysis, the court found Hill's motions riddled with citation problems: "Hazy v. Ford Motor Co., 2021 WL 2345678" does not exist; "Architex Ass'n v. Scottsdale Ins., 2022 WL 1234567" is "a fictional citation"; "Canal Ins. Co. v. Coleman, 625 So. 2d 297 (Miss. 1993)" is fictional; and a "Patterson v. Allstate" Westlaw number actually points to an unrelated Alabama labor case. The court was "concerned that what Hill has offered as legal authority is the result of output from generative artificial intelligence."
- AI tool:
- Unidentified (the court was 'concerned' the citations were generative-AI output; no tool named)
What sanction did the court impose?
The court denied all seven discovery motions, primarily because they were filed months after the April 1, 2025 discovery deadline and without the required good-faith certificates. It imposed no sanction for the fabricated citations. It warned Hill that "submitting documents containing AI hallucinations is sanctionable conduct, and pro se litigants are not immune from being sanctioned for it," and noted that even if she had not used AI, the citations still violated her Rule 11 obligation to ensure her legal contentions are warranted by existing law.
Why does Latasha Hill v. Auto Club Family Insurance Company matter for law firms using AI?
Hill v. Auto Club Family Insurance is a useful illustration of how AI-citation problems surface inside an ordinary discovery dispute. The AI issue was not the subject of the motion. Hill filed seven late discovery motions; Magistrate Judge Rath denied all of them on timeliness and procedural grounds, and the fabricated citations came up only in the “good faith” prong of the excusable-neglect analysis.
That placement is the point. A court assessing whether a pro se litigant acted in good faith will treat fabricated citations as evidence on that question, even where the citations are not what the motion turns on. Judge Rath also made the Rule 11 point that recurs across these cases: whether or not Hill used AI, citing cases that do not exist or do not stand for the cited proposition independently violates Rule 11(b)(2). For a firm defending an insurer against a pro se plaintiff, the practical read is that flagging fabricated authority in a discovery response feeds directly into the good-faith and Rule 11 analysis the court is already running.