Maldonado v. Professional Animal Retirement Center
U.S. District Court, Northern District of Indiana, Fort Wayne Division · N.D. Ind. · Indiana bar guidance
Verified September 29, 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, self-proclaimed "Tiger King") that, the court found, included "citations to cases that existed but could not be located at the given citation and in no way supported the propositions for which they were cited, as well as multiple references to numerous cases which could be located but nevertheless in no way supported Maldonado's contentions." The errors "led the Court to suspect counsel used generative AI," and Chief Judge Holly A. Brady issued a Show Cause Order on February 27, 2026. Roots accepted responsibility but denied bad faith; the court noted that "[a]lthough he does not directly address the use of AI for the filings, that use can be read between the lines," pointing to his pledge about "AI-assisted or database-generated research summaries" and a paralegal's declaration referring to "Lexis research tools and AI-assisted research features." Roots withdrew nearly every standing-related citation through an "Errata and Corrected Authorities" submission.
- AI tool:
- Not identified (the court suspected generative AI; counsel did not directly address it, and a paralegal's declaration mentions "AI-assisted research features")
- 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 violations of Rule 11(b) (the decretal paragraph cites 11(b)(3)): $500 per offending filing plus $500 for his admitted failure to review, which the court called 'at the low end of fines imposed by courts in similar circumstances.' 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?
In Maldonado the fine was counted per filing. 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. The court also doubted counsel’s explanation that a wrong draft had been filed, and said the errors were “glaring” whether they were “the work of generative AI or counsel’s own sloppiness.”
Sources
Primary sources
- AI attribution: the court did not find that AI was used. It wrote: "Whether these incorrect filings are the work of generative AI or counsel's own sloppiness, the resulting errors and legal misrepresentations are glaring."