Jakes v. Youngblood
U.S. District Court, Western District of Pennsylvania · W.D. Pa. · Pennsylvania bar guidance
Verified April 26, 2026
- Citation
- Jakes v. Youngblood, No. 2:24-cv-01608 (W.D. Pa. Oct. 6, 2025)
- Decided
- October 6, 2025
Summary
Plaintiff's counsel Tyrone A. Blackburn, appearing pro hac vice for Bishop T.D. Jakes in a defamation action against Pastor Duane Youngblood, filed briefs containing fabricated quotations attributed to the court's own April 25, 2025 Memorandum Opinion and to Franklin Prescriptions, Inc. v. N.Y. Times Co., among other misrepresentations. After defense counsel flagged the fabricated authorities, Blackburn's reply brief repeated and added to the errors, and Blackburn accused opposing counsel of using AI rather than acknowledging his own misuse. Judge William S. Stickman IV found Blackburn had used a system with an "AI element" without verifying the output and concluded the conduct constituted clear ethical violations warranting sanction and revocation of his pro hac vice admission.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $5,000
What sanction did the court impose?
$5,000 monetary sanction payable to plaintiff's counsel in monthly installments of at least $500 beginning November 15, 2025; pro hac vice admission revoked; any future pro hac vice motion filed by Blackburn in the Western District of Pennsylvania must attach a copy of the sanctions order. Plaintiff's counsel had requested $76,197.63; the court denied the bulk of that request and imposed a $5,000 figure deemed sufficient to deter further misconduct.
Why does Jakes v. Youngblood matter for law firms using AI?
Jakes v. Youngblood is the first of at least two AI-hallucination sanctions imposed on attorney Tyrone A. Blackburn within roughly two months; the District of New Jersey sanctioned him again in Gardner v. Combs on December 15, 2025, expressly citing the Western District of Pennsylvania order as evidence of pattern conduct. The case is also notable for what the court sanctioned: not only fabricated citations, but fabricated direct quotations attributed to the court’s own prior opinion, a category of hallucination that is harder for opposing counsel to spot without pulling the underlying decision. For managing partners, the order underscores that pro hac vice admission can be revoked, not merely conditioned, when an out-of-state attorney files unverified AI output and then doubles down rather than withdrawing the brief.