Sharita Hill v. State of Oklahoma ex rel. Oklahoma Medical Marijuana Authority
U.S. District Court, Western District of Oklahoma · W.D. Okla. · Oklahoma bar guidance
Verified April 26, 2026
- Citation
- Hill v. Oklahoma ex rel. Okla. Med. Marijuana Auth., No. CIV-25-522-SLP, 2025 WL 1840659 (W.D. Okla. July 3, 2025) (Palk, J.)
- Decided
- July 3, 2025
Summary
In an employment retaliation and ADEA action, Plaintiff's counsel filed a Response brief whose case citations the Court reviewed and found to be "inaccurate, nonexistent and include direct quotes that cannot be located." Judge Scott L. Palk concluded the inaccuracies signaled that counsel "may have used AI to assist in the drafting of Plaintiff's Response (or otherwise counsel produced exceptionally sloppy work)." Counsel made no disclosure or certification under the Court's Chambers Rules governing generative AI use. The Court granted dismissal of the federal claims on the merits (Title VII protected-activity failure; ADEA barred by Eleventh Amendment sovereign immunity) and remanded the state Burk claim.
- AI tool:
- Implied (not disclosed by counsel)
- Sanction amount:
- None (admonishment only)
What sanction did the court impose?
Strong judicial admonishment to Plaintiff's counsel; no monetary sanction imposed. Counsel forewarned that the state court on remand may impose sanctions if similar inaccuracies recur. Federal claims dismissed; state-law Burk claim remanded to Oklahoma County District Court.
Why does Sharita Hill v. State of Oklahoma ex rel. Oklahoma Medical Marijuana Authority matter for law firms using AI?
Hill is a useful data point for the “warning, not sanction” tier of AI-citation cases. Judge Palk did not impose a monetary penalty, but the order publicly documents that counsel’s brief contained nonexistent cases and fabricated quotations, and it puts counsel on notice that the same conduct in state court on remand could draw sanctions. For a managing partner, the practical lesson is twofold: first, the Western District of Oklahoma already has standing Chambers Rules requiring affirmative disclosure of AI use and certification of citation accuracy, so a firm operating there cannot treat AI disclosure as discretionary; second, even where the court declines to sanction, the published order itself is a reputational event that travels with the attorney and the firm.
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.
- The specific generative AI tool used was not identified in the order; the Court framed AI use as a likely inference, not a confirmed fact, and noted "exceptionally sloppy work" as an alternative explanation.
- Identity of Plaintiff's counsel and the specific defective citations are not named in the order text reviewed.