Pauliah v. University of Mississippi Medical Center
U.S. District Court, Southern District of Mississippi, Northern Division · S.D. Miss. · Mississippi bar guidance
Verified May 5, 2026
- Citation
- Pauliah v. Univ. of Miss. Med. Ctr., No. 3:23-cv-3113-CWR-ASH (S.D. Miss. Dec. 30, 2025)
- Decided
- December 30, 2025
Summary
Pro se plaintiff Mohan Pauliah and his former counsel Samuel L. Begley submitted a 40-plus-page declaration opposing summary judgment that contained multiple fabricated quotations attributed to the deposition of Dr. Candace Howard, accompanied by manufactured pinpoint citations to deposition transcripts. Pauliah admitted using generative AI to draft portions of the declaration and admitted he did not review it before signing under penalty of perjury. Begley, who had himself taken the depositions, failed to verify the quotations against the transcripts in his possession. Judge Carlton W. Reeves struck the declaration as filed in bad faith and convened a Rule 56(h) hearing on sanctions.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $5,000
What sanction did the court impose?
$5,000 in total sanctions apportioned $4,000 against attorney Begley and $1,000 against Pauliah, both payable to defense firm Forman Watkins & Krutz LLP within 120 days. Begley was further ordered to complete a minimum of three hours of Mississippi CLE on AI-generated hallucinatory citations and submit proof to the Court within 120 days. The Court reduced the sanction from a calculated $8,570 in attributable fees after considering both sanctioned parties' economic circumstances.
Why does Pauliah v. University of Mississippi Medical Center matter for law firms using AI?
Pauliah is a notable variant of the now-familiar AI sanctions pattern. As Judge Reeves put it, “AI was used not to hallucinate the law, but to hallucinate the facts.” The fabrications here were not phantom case citations but invented deposition testimony, complete with manufactured transcript pinpoints designed to lend an appearance of authenticity. Firms whose verification protocols focus exclusively on case-law citations should expand them: every quotation attributed to a record source, including depositions, exhibits, and contracts, needs to be checked against the underlying document before filing.
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.