Nguyen v. Savage Enterprises
U.S. District Court, Eastern District of Arkansas, Central Division · E.D. Ark. · Arkansas bar guidance
Verified May 5, 2026
- Citation
- Nguyen v. Savage Enterprises, No. 4:24-cv-00815-BSM (E.D. Ark. Mar. 3, 2025)
- Decided
- March 3, 2025
Summary
Plaintiff Diane Nguyen cited nonexistent authority in her response to Savage Enterprises's motion to dismiss. After being ordered to show cause, she responded that artificial intelligence, along with counsels' heavy workload and personal issues, may have contributed to the errors, and apologized. Judge Brian S. Miller found the citations to fake opinions violated Rule 11(b).
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
Judge Miller imposed a $1,000 sanction payable into the registry of the court within fourteen days, characterizing the amount as on the low end of comparable AI-hallucination sanctions and citing Mata v. Avianca, Wadsworth v. Walmart, and United States v. Hayes for context.
Why does Nguyen v. Savage Enterprises matter for law firms using AI?
The Eastern District of Arkansas explicitly benchmarked its $1,000 sanction against Mata v. Avianca, Wadsworth v. Walmart, and United States v. Hayes. That framing matters: federal courts are now treating fake-citation sanctions as a settled category with a known dollar range, not a novel issue. An AI-blame explanation paired with an apology, the order makes clear, does not avoid Rule 11(b) liability when the underlying citations are fabricated.
Sources
Primary 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.