Sophia Madigan v. Graco Inc.
U.S. District Court, District of Minnesota · D. Minn. · Minnesota bar guidance
Verified May 5, 2026
- Citation
- Madigan v. Graco Inc., No. 24-cv-1416 (ECT/EMB), 2026 WL 296444 (D. Minn. Feb. 4, 2026) (Tostrud, J.)
- Decided
- February 4, 2026
Summary
Plaintiff's counsel Charlie R. Alden (Gilbert Alden Barbosa PLLC) cited two nonexistent cases in opposition to summary judgment in a pregnancy discrimination matter: "Hernandez v. Best Buy Co., 2012 WL 1970771 (D. Minn. May 31, 2012)" and "LaPoint v. Family Orthodontics, P.A., 2020 WL 6118773 (D. Minn. Oct. 16, 2020)." The Westlaw citation numbers resolved to a Sixth Circuit insurance dispute and an SEC fraud action, respectively, neither relevant to the Minnesota Parenting Leave Act or pregnancy accommodations issues for which they were cited. After opposing counsel flagged the problem, Alden emailed chambers acknowledging he used an AI-based legal-research service and that the citations were "incorrect," then later argued the fake cases related only to "small background points." Judge Eric C. Tostrud rejected that characterization, noting they were the only two cases cited on the MPLA and pregnancy accommodations claims.
- AI tool:
- Unspecified AI-based legal-research service
What sanction did the court impose?
No formal Rule 11 sanction. Judge Tostrud declined to issue a show-cause order, concluding "the better approach is to leave the issue where it is" because the conduct had been raised with counsel and counsel was expected to take steps to prevent recurrence. The court expressly noted counsel's responses did not reflect "clear or complete acceptance of responsibility." Summary judgment was granted to Graco on all five counts.
Why does Sophia Madigan v. Graco Inc. matter for law firms using AI?
Madigan illustrates the lighter end of the judicial response spectrum: a managing partner reading this opinion sees that even when fabricated citations are the sole authority for an entire argument section, a court may decline to formally sanction if it believes counsel got the message. That is not a defense plan. The opinion is published, the attorney is named, and Judge Tostrud’s remark that counsel’s “responses do not reflect clear or complete acceptance of responsibility” travels with the lawyer’s reputation regardless of whether a Rule 11 order issued. The case also reinforces that a plausible-looking Westlaw cite (correct reporter, real date) can resolve to an unrelated opinion in another circuit, which is the exact failure mode an AI-based research tool will not catch on its own.
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.