In re the Marriage of Amy Haddock and Justin Blu Haddock
District Court of Tulsa County, Oklahoma · Okla. Dist. Ct. (Tulsa Cnty.) · Oklahoma bar guidance
Conduct
Here a motion to dismiss had three citations to nonexistent law and three citations with inaccurate descriptions; counsel filed a corrected version without leave.
Consequence
Here the court fined counsel $2,000, sustained fees for the subpoenaed third-party son, asked the firm to audit its case bank, and said it would notify the state bar.
Lesson
Here the court held that relying on a paralegal's research does not shift the duty to ensure a pleading's law is accurate.
Verified September 28, 2026
- Citation
- In re Marriage of Haddock, No. FD-2021-987, Order (Okla. Dist. Ct., Tulsa Cnty. filed May 21, 2026) (Sparkman, Special J.) (hearing held Apr. 1, 2026)
- Decided
- May 21, 2026
Summary
In a Tulsa County divorce proceeding, the parties' adult son, Colbe Haddock, was subpoenaed as a third party and moved to quash. On April 30, 2025, the husband, through counsel, moved to dismiss the son's motion to quash. The court found that the husband's motion "contained three citations to nonexistent law and three citations to cases with inaccurate descriptions of the propositions of law for which they stood." The errant citations were pointed out to husband's counsel, N. Scott Johnson of Johnson & McCord, on August 25, 2025; he then sought leave to file a corrected motion and filed it before leave was granted. Johnson submitted an affidavit executed by his paralegal. The son moved for attorney fees and sanctions. At an April 1, 2026 hearing, where Johnson's appearance was excused on medical grounds and the husband appeared through Patrick McCord of the same firm, Special Judge Rodney Sparkman took up the son's motion along with the other pending motions. The order finds that the corrected filing did not moot the issue and that, even if a paralegal performs legal research, it is counsel's responsibility to ensure that the facts and law in a pleading are accurate.
- AI tool:
- Unidentified (the order finds citations to nonexistent law and inaccurate case descriptions but does not mention AI)
- Sanction amount:
- $2,000 sanction against attorney N. Scott Johnson, payable into the court fund within thirty days of the order's recited April 1, 2026 hearing date (the order was filed May 21, 2026); son's motion for fees sustained with the amount and liable parties set for a May 20, 2026 hearing; firm asked to audit its case bank, with McCord to report on the audit; order to be reported to the Oklahoma Bar Association
What sanction did the court impose?
The court sustained the son's motion for sanctions and fees, subject to a later determination of a reasonable fee, and set a May 20, 2026 hearing to fix the amount and "exactly against whom the judgment will be granted." After considering "a wide range of sanctions," and noting that it knew of no similar issue involving Johnson, whom it described as "a highly effective advocate" and whose conduct appeared to be "a one-time, one-filing event," the court sanctioned Johnson $2,000, payable into the court fund "within thirty (30) days of today's date" (the order recites the April 1, 2026 hearing as its date but was filed May 21, 2026). It asked the firm to review "their bank of cases" for invalid citations and directed McCord to report to the court and counsel on the process, procedures, and outcome of that audit. The court stated it would impose no additional sanctions but would contact the Oklahoma Bar Association about the order and its findings. The same order granted the son's motion to quash in part, denied the husband's sanctions motions against the son and against the wife and her counsel, and denied the husband's renewed motion in limine.
Why does In re the Marriage of Amy Haddock and Justin Blu Haddock matter for law firms using AI?
The Tulsa County order is notable for what it did not rely on. It makes no finding that AI was used; the court’s concern was the signature. “The issue before the Court is basically, for me, trustworthiness and basically an attorney’s ethics on their filings because the attorney signs off on those pleadings attesting that they know all of this is true and correct.” The court declined to make a finding, based on the paralegal’s affidavit, that similar cases had been filed, and rested instead on the principle that a paralegal’s research does not transfer the attorney’s responsibility for the accuracy of the pleading.
The sanction package mixes a modest fine with structural measures. The court weighed Johnson’s long record before it and treated the conduct as a single filing, but still imposed $2,000, sustained fee-shifting in favor of the son, and asked the firm to review its “bank of cases,” with McCord to report back so the court could “know that the bank is not containing invalid cites for future reference.” It closed by stating it would contact the Oklahoma Bar Association about the order and its findings.
The order also shows the procedural consequence of self-help correction. Counsel filed a corrected motion to dismiss after seeking leave but before the court ruled on it, and the court held that “the mere filing of the corrected Motion does not moot the issue from the Court’s perspective.” Firms documenting compliance may wish to consider recording who maintains any reusable library of authorities and how often it is re-verified.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Review any internal bank of cases or template authorities. The court asked the firm to go through its bank of cases and directed McCord to report on the process, procedures, and outcome of the audit.
- Document attorney review of research performed by paralegals. The court held that accuracy of the law in a pleading is counsel's responsibility, not the paralegal's.
- Consider that a corrected filing does not end the inquiry. The court found the unauthorized corrected motion did not moot the sanctions issue.
Sources
Primary sources
- OSCN, Oklahoma State Courts Network (primary source)
- OSCN, Oklahoma State Courts Network (primary source)
- AI attribution is a Charlotin tracker inference; the order does not mention artificial intelligence.
- The amount of the later fee award (the docket shows an Order on Attorney's Fees filed May 27, 2026) was not read; the Charlotin tracker's figure for it is not relied on here.