Jackson v. Auto-Owners Insurance Company
U.S. District Court, Middle District of Georgia · M.D. Ga. · Georgia bar guidance
Verified April 26, 2026
- Citation
- Jackson v. Auto-Owners Ins. Co., No. 7:24-cv-00136 (M.D. Ga. July 14, 2025)
- Decided
- July 14, 2025
Summary
Plaintiff's counsel in Woodrow Jackson's coverage dispute against Auto-Owners filed a response to a motion to dismiss that included nine case citations, one of which neither the court nor opposing counsel could locate in any reporter or database. The court found the citation fabricated and attributed the error to unverified use of generative AI in legal research. Counsel was ordered to pay a monetary sanction, complete continuing legal education on AI in legal practice, and bear opposing counsel's costs in addressing the fabricated authority.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 monetary sanction against plaintiff's counsel, a continuing legal education requirement on the responsible use of AI in legal research and writing, and an adverse costs order requiring counsel to reimburse opposing counsel's fees incurred responding to the fabricated citation.
Why does Jackson v. Auto-Owners Insurance Company matter for law firms using AI?
Jackson illustrates that even a single fabricated citation, in a routine insurance coverage dispute far from the headline AI sanctions docket, is enough to trigger a four-figure fine, a CLE mandate, and a costs award. For a 5-50 attorney firm, the lesson is that the sanction floor is not reserved for repeat offenders or high-profile filings: a single unchecked citation in a motion response can produce a public discipline record tied to the firm’s name.
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.
- Specific name of presiding judge and sanctioned attorney not independently verified outside the order PDF.
- Identity of the specific AI tool used was not disclosed in available secondary sources; order text controls.