Lewis v. Entergy Mississippi, LLC
U.S. District Court, Southern District of Mississippi, Northern Division · S.D. Miss. · Mississippi bar guidance
Verified April 26, 2026
- Citation
- Lewis v. Entergy Mississippi, LLC, No. 3:25-cv-323-HTW-ASH (S.D. Miss. Sept. 3, 2025)
- Decided
- September 3, 2025
Summary
Magistrate Judge Andrew S. Harris issued a sua sponte order to show cause against plaintiff Blake Lewis's counsel after identifying multiple defective citations in the opposition brief to Entergy's motion to stay. The order flags a fabricated authority, "Matherne v. Cytec Corp., 78 F. App'x 977 (5th Cir. 2003)," which the court could not locate in Westlaw, LexisNexis, vLex Fastcase, or Google Scholar; the cited reporter page actually contains an unrelated criminal appeal. The order also flags "Von Drake v. Nat'l Sec. Agency, 156 F.3d 181, 1998 WL 546172 (5th Cir. 1998)," which does not exist at the cited locations, and Fujita v. United States, 416 F. App'x 400 (5th Cir. 2011), cited for a holding directly contrary to the actual opinion (which affirmed a stay rather than reversing one).
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Counsel who signed the brief was ordered to file a written response and declaration under penalty of perjury by September 12, 2025, showing good cause why sanctions should not issue under Federal Rule of Civil Procedure 11(b), Mississippi Rule of Professional Conduct 3.3, Local Rule 83.1(c)(1), or the court's inherent authority. Co-counsel were permitted to join the response and address Mississippi Rule 5.1 supervisory duties.
Why does Lewis v. Entergy Mississippi, LLC matter for law firms using AI?
The Lewis order is notable for two reasons firms should track. First, the court identified the same counsel making contradictory uses of Fujita on the same day in a related case, Dyess v. Entergy Mississippi, No. 3:25-cv-326-CWR-ASH, suggesting the citation problems were systemic across the firm’s filings rather than an isolated lapse. Second, Judge Harris expressly invoked Mississippi Rule 5.1 in inviting co-counsel to address supervisory responsibility, a reminder that managing partners and supervising attorneys are exposed when associates file AI-generated work.
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.