Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC
U.S. District Court for the Southern District of Indiana · S.D. Ind. · Indiana bar guidance
Verified April 24, 2026
- Citation
- Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC, No. 2:24-cv-00326-JPH-MJD, 2025 WL ____ (S.D. Ind. Feb. 21, 2025) (Report and Recommendation)
- Decided
- May 28, 2025
Summary
Defense counsel Rafael Ramirez submitted three briefs containing citations to non-existent cases generated by AI tools. Magistrate Judge Mark J. Dinsmore identified fabricated citations in three separate pleadings (Dkts. 39, 52, and 65), including a non-existent In re Cook County Treasurer, 773 F.3d 834 (7th Cir. 2014); Knoedler Manufactuers, Inc. v. Cox, 545 F.2d 1033 (7th Cir. 1976); and Brown v. Local 58, IBEW, 628 F.2d 441 (6th Cir. 1980). At a January 3, 2025 show-cause hearing, Ramirez admitted he had relied on programs utilizing generative AI to draft the briefs and did not verify the citations. The underlying case is an ERISA dispute between a health-and-welfare fund and HoosierVac LLC.
- AI tool:
- Generative AI (unspecified)
- Sanction amount:
- $6,000
What sanction did the court impose?
On February 21, 2025, Magistrate Judge Dinsmore issued a Report and Recommendation recommending Ramirez be sanctioned $15,000 ($5,000 per brief) under Federal Rule of Civil Procedure 11, and referred the matter to Chief Judge Tanya Walton Pratt under Local Rule of Disciplinary Enforcement 2(a) for consideration of additional discipline. The R&R found violations of Fed. R. Civ. P. 11(b) and Indiana Rules of Professional Conduct 1.1 (Competence), 3.1 (Meritorious Claims), and 3.3 (Candor Toward the Tribunal). District Judge James Patrick Hanlon subsequently imposed $6,000 in sanctions on May 28, 2025, reducing the magistrate's recommended amount.
Why does Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC matter for law firms using AI?
Mid Central v. HoosierVac confirms that the Southern District of Indiana will sanction attorneys for AI-hallucinated citations and refer them to state bar regulators. The magistrate’s original $15,000 recommendation (scaled down to $6,000) signals serious disapproval of unchecked AI use, and the bar referral removes any suggestion that federal sanctions alone resolve the matter. For Indiana attorneys, the case establishes that failure to verify AI output violates not only procedural rules (Fed. R. Civ. P. 11) but also substantive professional-conduct rules.
Sources
Primary sources
Further reading
- Specific AI tool used: the February 21, 2025 R&R describes only 'programs utilizing generative artificial intelligence' without naming a product (e.g., ChatGPT); no specific tool is identified in the primary source.
- District Judge Hanlon's final $6,000 sanction order dated 2025-05-28 has not been verified against its primary order text; the figure and date come from secondary coverage and prior project notes. The Feb 21, 2025 R&R recommended $15,000.
- Whether the bar referral to Chief Judge Pratt resulted in additional Indiana Attorney Disciplinary Commission action has not been verified.