Hodges v. Meridian Waste Acquisitions, LLC (consolidated with Rieske v. Accounting Fulfillment Services, LLC)
U.S. District Court, Middle District of Florida, Jacksonville Division · M.D. Fla. · Florida bar guidance
Verified April 26, 2026
- Citation
- Hodges v. Meridian Waste Acquisitions, LLC, No. 3:25-cv-00062 (M.D. Fla. Jan. 16, 2026) (Corrigan, J.) (consolidated with Rieske v. Accounting Fulfillment Servs., LLC, No. 5:25-cv-00045)
- Decided
- January 16, 2026
Summary
Senior U.S. District Judge Timothy J. Corrigan sanctioned plaintiffs' counsel Noah E. Storch of Celler Legal, P.A., after Storch filed briefs containing AI-generated fabricated case citations across two related Fair Labor Standards Act actions, Hodges v. Meridian Waste Acquisitions, LLC and Rieske v. Accounting Fulfillment Services, LLC. The cited authorities either did not exist, did not stand for the propositions asserted, or could not be located in conventional legal research databases. Storch acknowledged using AI assistance and failing to verify the output before filing.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $7,000
What sanction did the court impose?
$7,000 in defendants' attorney fees ordered paid by Storch personally. The court also required Storch to give ten public talks within one year at bar associations or to law students about his experience, complete CLE on legal ethics and AI, arrange firm-wide CLE on the same topics, notify affected clients, and submit written apologies to the court and to opposing counsel.
Why does Hodges v. Meridian Waste Acquisitions, LLC (consolidated with Rieske v. Accounting Fulfillment Services, LLC) matter for law firms using AI?
Hodges is the most striking 2026 sanctions order on AI-fabricated citations to date because the remedy goes well past money. Judge Corrigan’s combination of fee shifting, mandatory public speaking at bar events or law schools, layered CLE, client notification, and written apology turns one attorney’s filing error into a year-long professional reputation event. For a managing partner, the case underscores that courts are now treating unverified AI output as a firm-governance failure, not just an individual lapse: the order reaches the firm’s CLE program, not only the lawyer who signed the brief.
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.