Alexandria Jones v. District of Columbia Office of Unified Communications
U.S. District Court, District of Columbia · D.D.C. · District of Columbia bar guidance
Verified April 26, 2026
- Citation
- Jones v. District of Columbia Office of Unified Communications, No. 25-cv-1129 (RC), 2025 WL 2977585 (D.D.C. Oct. 22, 2025) (Contreras, J.)
- Decided
- October 22, 2025
Summary
Plaintiff's counsel Donald Quinn submitted an opposition brief to a partial motion to dismiss that "persistently attribute[d] quotations to cases that do not contain the quoted material." Judge Rudolph Contreras found that the citations "bear the hallmarks of reliance on an artificial intelligence tool" and identified apparent violations of Federal Rule of Civil Procedure 11(b)(2) and D.C. Rule of Professional Conduct 3.3(a)(1). The court did not impose a monetary sanction but issued an explicit warning.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. Mr. Quinn was "advised that further violations will not be tolerated and may result in sanctions and/or referral to a disciplinary committee." The court separately granted defendant's partial motion to dismiss, dismissing Counts II and V in their entireties and Count III to the extent it relied on Title VII.
Why does Alexandria Jones v. District of Columbia Office of Unified Communications matter for law firms using AI?
Jones is a “warning shot” precedent rather than a sanctions order, but it is exactly the kind of opinion a managing partner should treat as a near-miss. The court did not need to find the underlying cases were fictitious; it was enough that the quotations attributed to real cases did not appear in those cases. For firms drafting AI-use policies, the lesson is that a verification protocol must check quoted language against the cited opinion, not just confirm that the case exists, and that even an unsanctioned warning under Rule 11 and Rule 3.3 creates a paper trail a future tribunal or malpractice carrier can use.
Sources
Further reading
- CourtListener docket search (aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
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.
- CourtListener docket URL not directly confirmed; the Westlaw cite (2025 WL 2977585) and the Charlotin S3 mirror of the slip opinion are the verified primary-equivalent sources.