Nora v. M & A Transport, Inc.
U.S. District Court, Eastern District of Louisiana · E.D. La. · Louisiana bar guidance
Verified April 26, 2026
- Citation
- Nora v. M & A Transport, Inc., No. 24-cv-2098 (E.D. La. Aug. 13, 2025) (Morgan, J.)
- Decided
- August 13, 2025
Summary
Plaintiff's counsel Ms. Hamilton filed a Motion to Transfer Venue containing three defective citations: a real case caption (Gallagher v. Wilton Enterprises) paired with a citation pointing to a different case, a nonexistent decision (Mader v. Advanced Neuromodulation Sys.), and a real case (Krapf v. St. Luke's Hosp.) cited for a proposition it does not support. Counsel acknowledged the authorities were generated and mistakenly verified using Westlaw Precision. Judge Susie Morgan found violations of Rule 11(b)(2) and (3) for filing fabricated, AI-generated authorities without verification.
- AI tool:
- Westlaw Precision (AI-assisted research)
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 monetary sanction payable by Ms. Hamilton personally (not by her firm or client), one hour of CLE on generative AI, and referral to the Disciplinary Committee of the U.S. District Court for the Eastern District of Louisiana.
Why does Nora v. M & A Transport, Inc. matter for law firms using AI?
Nora illustrates a subtler failure mode than wholesale fabrication: a vendor-branded “AI-assisted” research tool produced output that mixed a real caption with the wrong reporter cite and miscast a real case’s holding. For a managing partner, the takeaway is that “we only use Westlaw, not ChatGPT” is not a defense. Verification against the actual opinion text, not the AI summary, is the only reliable check, and the court here imposed personal (not firm) liability on the filing attorney.
Sources
Primary sources
Further reading
- Exact civil action number not confirmed from the order text; CourtListener docket page (PACER ID 273478) was not directly retrievable during verification.