Pettit v. Allina Health System

What sanction did the court impose?

In a January 30, 2025 Order and Report and Recommendation, the magistrate judge ordered Hechter to pay Allina $9,752.50 in fees on its earlier motion to compel, and recommended that the case be dismissed with prejudice and that Hechter and his firm pay $10,000, jointly and severally, toward Allina's fees and costs as the Rule 11 sanction. The recommendation rested on both the copied factual allegations and the misrepresented probate decision; the court called it "disturbing irony" that the false legal statement was made in opposing a Rule 11 motion. It rejected Allina's request to sanction Pettit personally, calling that tactic "cruel." No objections were filed. On March 25, 2025, Judge Jerry W. Blackwell accepted the recommendation on clear-error review, dismissed the amended complaint with prejudice, ordered Hechter and Morris Law Group to pay $10,000, and denied fees against Pettit. The court had earlier granted Hechter's motion to withdraw. The orders make no disciplinary referral.

Why does Pettit v. Allina Health System matter for law firms using AI?

Pettit is chiefly a pleading case, and the citation problem is a secondary but expressly relied-on ground. Magistrate Judge Docherty found that Hechter copied allegations from another employee’s discrimination complaint against Allina into both of Pettit’s complaints, including allegations about named supervisors who, Pettit testified, never supervised her, and that she had told him the complaint was not ready to be filed. The court said it was “difficult” to identify “a more obvious violation” of Rule 11(b)(3).

The citation came later, in Hechter’s memorandum opposing Allina’s Rule 11 motion. He cited a probate matter from the estate of Prince Rogers Nelson for the proposition that an award of complete attorneys’ fees would be “grossly improper.” The court explained in a footnote that the decision “was not easy to find,” because none of the Minnesota Court of Appeals opinions in the Prince probate proceedings address sanctions. Once it located the 2016 district court decision, it found the ruling “does not say what Mr. Hechter represents it says, or even anything close.” Magistrate Judge Docherty concluded that “[m]isrepresenting the legal significance of a case or the holding in a case is a violation of Rule 11(b)(2),” and noted that Hechter “violated Rule 11 in his efforts to avoid sanctions for his previous violations of Rule 11.” The orders do not suggest the citation came from an AI tool; the Charlotin tracker’s AI attribution is an inference. The report found no “malice or intent to cause harm,” while also describing “deliberate misrepresentations to the court,” and recommended dismissal both as a sanction and because, once the false and copied statements are removed, “there are no well-pleaded allegations” of a race-based hostile work environment. With a separate $9,752.50 discovery sanction, the report put the total sanctions in the case at $19,752.50.

The sanction combined dismissal with prejudice and a $10,000 payment by Hechter and his firm, jointly and severally, which the court described as less than Allina spent defending the case and “sufficient, but not greater than,” what was needed to deter similar conduct. The court declined to sanction Pettit herself. Firms documenting compliance may wish to consider that here the court checked an obscure, unreported authority itself, and that a misdescribed case cited in a sanctions opposition became a further basis for the sanction the filing was meant to avoid.