Lafontant v. Coolidge-CLK St. Germane, LLC
U.S. District Court, Eastern District of Louisiana · E.D. La. · Louisiana bar guidance
Verified April 26, 2026
- Citation
- Lafontant v. Coolidge-CLK St. Germane, LLC, No. 24-cv-2536 (SM)(KWR), Doc. 53 (E.D. La. Oct. 2, 2025) (Morgan, J.)
- Decided
- October 2, 2025
Summary
Plaintiff's counsel Pius A. Obioha signed and filed a summary judgment opposition that cited Miller v. Housing Authority of New Orleans, a case neither defendants nor the court could locate, and Boudreaux v. Boudreaux for tenant-rights and non-waiver propositions, when the actual Boudreaux opinion addresses whether a principal was a statutory employer and has no relation to landlord/tenant law. Obioha admitted under oath that a law clerk drafted the brief, that he delegated review to another lawyer, and that he did not check the cases before signing. Judge Susie Morgan found the conduct violated Federal Rule of Civil Procedure 11(b)(2), expressly characterizing the Miller citation as "fabricated, AI-generated."
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 personal sanction (not payable by the firm or client) due November 3, 2025; one hour of CLE on generative AI required by January 31, 2026; referral to the Disciplinary Committee of the Eastern District of Louisiana.
Why does Lafontant v. Coolidge-CLK St. Germane, LLC matter for law firms using AI?
Lafontant tracks the now-standard E.D. La. sanction package, mirroring Judge Morgan’s earlier Nora v. M & A Transport order: a $1,000 personal payment, mandatory generative-AI CLE, and a disciplinary-committee referral. For managing partners, the order is notable less for its dollar amount than for what it deems irrelevant: the sanctioned attorney did not draft the brief, blamed an associate and a law clerk, and accepted responsibility immediately, yet Rule 11 liability attached at the signature line. Delegating drafting without a citation-verification step before filing is, in this district, a documented sanctions risk.
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.