Master Textile Mills, Ltd. v. RSA Global Logistics, LLC
U.S. District Court, Eastern District of Pennsylvania · E.D. Pa. · Pennsylvania bar guidance
Conduct
Here plaintiff's counsel cited Local Rule 56.1 for a filing the rule does not address; the court said the citation created suspicion of unchecked generative AI use.
Consequence
Here the court denied both summary judgment motions as untimely, warned counsel to ensure all citations are accurate, and cautioned the parties about sanctions.
Lesson
Here a single miscited local rule was enough for the court to raise generative AI on the record and warn counsel, without any finding that AI was used.
Verified September 29, 2026
- Citation
- Master Textile Mills, Ltd. v. RSA Glob. Logistics, LLC, No. 2:25-cv-00515-GAW, Order (E.D. Pa. Nov. 13, 2025) (Weilheimer, J.), ECF No. 49
- Decided
- November 13, 2025
Summary
After the court struck the parties' first cross-motions for summary judgment on November 4, 2025 for failing to follow its published procedures and invited only motions to reinstate, both parties instead refiled their summary judgment motions on November 8, 2025. In its November 13, 2025 order, Judge Gail A. Weilheimer wrote further "to specifically note some of Plaintiff's counsel's shortcomings." Plaintiff Master Textile's refiled motion included a unilateral statement of undisputed facts that the judge's guidelines expressly prohibit, and it cited Local Rule 56.1 as supporting that filing, although the rule "addresses only 'Judgments pursuant to a Warrant of Attorney.'" The court said this citation "creates suspicion that counsel is relying heavily on generative artificial intelligence and not properly checking the citations it produces." It also noted exhibits that were not text searchable and were each named only "Exhibit."
- AI tool:
- Suspected, not found (the court said a miscited local rule "creates suspicion that counsel is relying heavily on generative artificial intelligence and not properly checking the citations it produces"; no tool is named and no AI use is found)
What did the court warn about?
The court denied both cross-motions for summary judgment as untimely and set the case for a pretrial conference. On the citation, it wrote: "Attorneys across the country have been sanctioned for that sort of behavior. Counsel is warned to ensure all citations in filings with the Court are accurate." It closed by cautioning the parties "that any further violations of this Court's procedures will result in this Court strongly considering sanctions." No sanction was imposed.
Why does Master Textile Mills, Ltd. v. RSA Global Logistics, LLC matter for law firms using AI?
Master Textile Mills v. RSA Global Logistics is a short summary judgment order in which the AI issue arises from a single citation. After the court struck the parties’ first summary judgment filings for failing to follow its published procedures, the plaintiff’s refiled motion cited Local Rule 56.1 as supporting a unilateral statement of undisputed facts. The court noted that the rule addresses only judgments pursuant to a warrant of attorney.
The court did not find that AI was used. It said the citation “creates suspicion that counsel is relying heavily on generative artificial intelligence and not properly checking the citations it produces,” observed that attorneys have been sanctioned for that behavior, and warned counsel “to ensure all citations in filings with the Court are accurate.” The warning sat alongside other procedural criticism: the prohibited statement of facts, exhibits that were not text searchable, and exhibits named only “Exhibit.” Both motions were denied as untimely, and the parties were cautioned that further violations would lead the court to consider sanctions strongly.
Firms documenting compliance may wish to consider that, here, the citation drawing the AI comment was to a local rule rather than to a case, a category that case-focused citation checks can miss.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Check local rule citations against the rule's text, not only case citations. Here the court treated a local rule cited for a proposition it does not address as creating suspicion of unchecked AI output.
- Follow a judge's individual guidelines on statements of fact and exhibits. Here the court listed those violations with the citation problem when it warned counsel.
Sources
Primary sources
- AI attribution: the court states only a 'suspicion' that counsel relied on generative AI, based on one miscited local rule; it makes no finding that AI was used. The tracker's AI coding rests on that language.