Montes v. Suns Legacy Partners LLC
U.S. District Court, District of Arizona · D. Ariz. · Arizona bar guidance
Verified May 5, 2026
- Citation
- Montes v. Suns Legacy Partners LLC, No. 2:25-cv-01295 (D. Ariz. Mar. 31, 2026) (Snow, J.)
- Decided
- March 31, 2026
Summary
Plaintiff's counsel Sheree Wright filed three motions in an employment discrimination action against the Phoenix Suns organization that contained at least 18 defective citations: three wholly fabricated cases attributed to real federal judges, plus multiple real cases miscited or cited for propositions they did not support. Wright attributed the filings to a staff member submitting drafts while she was on bereavement leave. Senior District Judge G. Murray Snow rejected that explanation as a "convoluted tale" and held Wright personally responsible for the AI-generated content under Rule 11.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court ordered Wright to pay defendants' reasonable attorneys' fees incurred responding to the offending filings (defendants had sought $144,390; the precise awarded amount was reserved for further fee determination), required her to complete additional CLE training on the ethical use of generative AI, and directed that the sanctions order be transmitted to the State Bar of Arizona and circulated to all district and magistrate judges in the District of Arizona.
Why does Montes v. Suns Legacy Partners LLC matter for law firms using AI?
Montes is notable for the breadth of the contamination, eighteen defective references across three motions, and for the court’s flat rejection of the “rogue staffer” defense that has surfaced in several 2025-2026 sanctions opinions. For a managing partner, the operative lesson is supervisory: Rule 11 attaches to the signing attorney regardless of whether a paralegal, associate, or AI tool produced the underlying draft, and a plausible-sounding delegation narrative will not insulate counsel when the citations themselves are fabricated. The collateral consequences here, mandatory CLE plus distribution of the order to the state bar and to every federal judge in the district, function as a reputational sanction that outlasts the fee award.
Sources
Primary sources
Further reading
- https://www.kjzz.org/2026-04-01/lawyers-for-ex-phoenix-suns-employee-suing-team-face-penalties-for-using-ai-in-legal-filings
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
- Leagle (legal aggregator)
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.
- Final dollar amount of the fee award (defendants requested $144,390; the order on its face directs payment of reasonable fees but the exact figure was not confirmed from the order text).
- Specific generative AI product used was not identified by name in available reporting; Wright reportedly self-reported to the state bar and her firm has since barred AI use.
- Number of CLE hours required was not specified in available reporting.