Mundy v. Clickstop, Inc.
District Court of Nebraska, Douglas County · Neb. Dist. Ct. (Douglas Cnty.) · Nebraska bar guidance
Verified April 26, 2026
- Citation
- Mundy v. Clickstop, Inc., No. CI 23-6600, 2025 WL 3073933 (Neb. Dist. Ct. Douglas Cnty. Oct. 17, 2025)
- Decided
- October 17, 2025
Summary
Plaintiffs' counsel James E. Harris filed multiple summary judgment briefs containing fabricated Nebraska case citations and quotations generated by AI, including the nonexistent "Hogan v. Norfleet, 191 Neb. 123," "Schiavone Construction Co. v. Time Equipment Rental, Inc., 205 Neb. 442," and "Panhandle Coop. Ass'n v. Whirlpool Corp., 250 Neb. 667," along with miscited authority and a fabricated quotation attributed to Rahmig v. Mosley Mach. Co. After defense counsel and the court flagged the errors, Harris filed a corrective brief that itself contained an additional hallucinated Restatement (Third) of Torts quotation. Judge James M. Masteller found Harris' failure to verify AI output was tantamount to bad faith.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $2,000
What sanction did the court impose?
Court struck Plaintiffs' motions and briefs filed on or after July 28, 2025; imposed $2,000 monetary sanction payable to the Clerk by November 25, 2025; ordered an ongoing AI-use certification requirement for all future filings by Harris in the case; and referred Harris to the Nebraska Counsel for Discipline.
Why does Mundy v. Clickstop, Inc. matter for law firms using AI?
Mundy is notable for two reasons that should concern any managing partner overseeing AI use. First, the sanctioned attorney was a known practitioner who had attended multiple AI training sessions, yet still filed five separate briefs containing fabricated Nebraska authority. Second, the corrective filing submitted in response to the show cause order itself contained a new hallucinated quotation, demonstrating how AI errors compound when verification protocols are inadequate. The court’s standing AI-use certification requirement, now imposed on all of Harris’ future filings in the case, is a forward-looking remedy firms should anticipate seeing more often.
Sources
Further reading
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.