Maldonado v. Professional Animal Retirement Center
U.S. District Court, Northern District of Indiana, Fort Wayne Division · N.D. Ind. · Indiana bar guidance
Verified April 26, 2026
- Citation
- Maldonado v. Pro. Animal Ret. Ctr., No. 1:25-cv-00454-HAB-ALT (N.D. Ind. Apr. 1, 2026)
- Decided
- April 1, 2026
Summary
Plaintiff's counsel Roger Roots filed a Complaint and response brief on behalf of Joseph Maldonado (the incarcerated former "Tiger King") that contained citations to cases that did not exist at the given citations and multiple other authorities mischaracterized to support an Endangered Species Act standing argument. After Chief Judge Holly A. Brady issued a Show Cause Order on February 27, 2026, Roots's response and an accompanying paralegal declaration acknowledged that filings had drawn on AI-assisted research tools. Roots withdrew nearly every standing-related citation through an "Errata and Corrected Authorities" submission.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,500
What sanction did the court impose?
Court dismissed the case for lack of Article III standing and ordered Roots to pay $1,500 to the Clerk of Court for Rule 11(b)(3) violations ($500 per offending filing plus $500 for failure to review). Court directed the Clerk to transmit the Opinion and the Show Cause Order to the Office of Chief Disciplinary Counsel for the Rhode Island Judiciary, where Roots is licensed.
Why does Maldonado v. Professional Animal Retirement Center matter for law firms using AI?
Maldonado is a useful pattern case for managing partners because the sanction tracks the number of tainted filings, not the prominence of the matter. The court billed $500 per filing that relied on misrepresented or nonexistent authority, plus $500 for the signing attorney’s failure to read what he filed, and added an out-of-state bar referral on top. A firm’s exposure scales with how many briefs go out the door before anyone catches the AI-generated citations.
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.