Lipe v. Albuquerque Public Schools
U.S. District Court, District of New Mexico · D.N.M. · New Mexico bar guidance
Verified April 26, 2026
- Citation
- Lipe v. Albuquerque Pub. Schs., No. 1:23-cv-00899-GBW-JMR (D.N.M. Sept. 22, 2025)
- Decided
- September 22, 2025
Summary
Plaintiff's counsel Boglarka Foghi filed an Objections brief, a Notice of Errata, and a Reply that together cited multiple nonexistent cases and attributed a fabricated quotation to Ogden v. San Juan Cnty., 32 F.3d 452 (10th Cir. 1994). At the show-cause hearing, Foghi conceded that unreviewed use of AI products by her paralegal and a legal contractor was the only explanation for the fake citations and fictional quotations. Chief Magistrate Judge Gregory B. Wormuth found a Rule 11(b)(2) violation, emphasizing that verifying authorities is a nondelegable duty.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $3,000
What sanction did the court impose?
$3,000 fine payable to the Clerk of Court for the District of New Mexico within 10 days, plus a requirement that counsel self-report the incident to both the New Mexico and Arizona state bar disciplinary boards within 30 days and submit proof of compliance to the court by October 31, 2025.
Why does Lipe v. Albuquerque Public Schools matter for law firms using AI?
Lipe is a useful teaching case for managing partners because the court was explicit that the underlying failure was not the use of AI, but the delegation of citation drafting to non-attorneys without verification. The order treats Shepardizing as a baseline professional obligation that predates generative AI by decades, and rejects a CLE course alone as adequate deterrence where the attorney repeatedly filed unreviewed citations across three separate filings. The cross-jurisdictional bar self-report requirement, covering both New Mexico and Arizona, signals that federal magistrate judges are willing to push discipline into multiple state systems for a single incident.
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.