Moorehead v. Goodwill Industries of Northeast Texas
U.S. District Court, Eastern District of Texas · E.D. Tex. · Texas bar guidance
Verified May 14, 2026
- Citation
- Moorehead v. Goodwill Indus. of Ne. Tex., No. 4:25-cv-00563-SDJ-BD (E.D. Tex. Nov. 18, 2025) (Davis, M.J.)
- Decided
- November 18, 2025
Summary
Alexandra Moorehead, proceeding pro se, sued Goodwill Industries of Northeast Texas in the Eastern District of Texas. Goodwill moved to stay discovery, and in the briefing the court found that Moorehead had cited three cases that do not exist: Turner v. Palo Alto Networks, Inc.; In re Caterpillar Inc.; and Waguespack v. Medtronic, Inc. A real Waguespack v. Medtronic exists, but it does not stand for the propositions Moorehead drew from it and was not decided within the Fifth Circuit. The court wrote that it "suspects that these citations are the result of hallucinations by generative artificial intelligence."
- AI tool:
- Unidentified (the court suspected the citations were 'hallucinations by generative artificial intelligence'; no specific tool named)
What sanction did the court impose?
The court denied Goodwill's motion to stay discovery on the merits and admonished Moorehead for the fabricated citations. It imposed no monetary sanction, but warned under Federal Rule of Civil Procedure 11(c) that "if Moorehead files another document that contains hallucinated or otherwise nonexistent citations, she will be subject to sanctions."
Why does Moorehead v. Goodwill Industries of Northeast Texas matter for law firms using AI?
Moorehead v. Goodwill is a clean example of a court separating the merits from the AI problem and handling each on its own track. Goodwill moved to stay discovery. The court denied that motion on its merits. Then, in the same order, it turned to the briefing and found three citations that do not exist, plus a fourth, a real Waguespack v. Medtronic, cited for propositions the case does not contain and pulled from outside the Fifth Circuit.
The court named generative AI as the suspected source and made the standard pro se point: proceeding without counsel “in no way relieves her of responsibility” for citing cases that are tantamount to dishonesty. It admonished Moorehead rather than sanctioning her, and tied the warning to Rule 11(c), so the next filing with hallucinated citations draws sanctions. For a firm litigating against a pro se opponent in E.D. Tex., the order is worth keeping as a citation for two propositions at once. An AI-citation problem does not bootstrap a weak discovery motion into a winner, and a first offense usually buys an admonishment plus a Rule 11 marker for next time.