Pittman v. Hazel and Olive, Inc.

What sanction did the court impose?

Citing counsel's bad-faith motion to enforce the settlement agreement, his "repeated lack of candor toward the Court," his "disingenuous use of discovery to generate fees," and his "negligent reliance on artificial intelligence that cited fake cases," the court ordered "as a sanction that this case is dismissed with prejudice and that Plaintiff's counsel must cover all costs and fees incurred by Defendant in defending this lawsuit." The parties were to meet and confer on the total, with any fees from that process also borne by counsel, and the case would be dismissed with prejudice once payment was finalized. The court granted the motion to strike, denied the motion to enforce the settlement, denied the motion to dismiss as moot, set a March 30, 2026 deadline for a joint status report on payment, and directed counsel to send a copy of the order to the Illinois ARDC. The order does not state a dollar amount. The CourtListener docket read on September 30, 2026 shows no entry after the March 19 order.

Why does Pittman v. Hazel and Olive, Inc. matter for law firms using AI?

Pittman is a case in which fabricated citations became one of several grounds for ending the litigation. The court’s March 19, 2026 order addresses four problems in turn: a motion to enforce a settlement agreement the client had rejected, which the court found was filed in bad faith and violated Model Rule 1.2 and Rule 11; incomplete disclosures in response to the court’s order about the settlement, which it found violated counsel’s duty of candor; discovery served before the Rule 26(f) conference, followed by a signed declaration that no discovery had been served; and a response brief that relied on artificial intelligence and cited fake cases. On the last, the order is brief: counsel admitted relying on AI, failing to cite-check, and submitting fake cases, and the court held that he violated Rule 11 in filing the response.

The record before the order shows how the court handled the citations. The defendant moved to strike the response on January 13, 2026 (R. 35). The court’s January 14 minute order stated that it had itself identified at least two citations to cases that do not exist, struck the response in the interim, and required counsel to address both the false citations and the bad-faith allegations. A later minute order noted that counsel’s response admitted relying on AI to generate false citations but did not substantively address the other issues, and required a sworn submission that included a list of any prior sanctions against counsel.

The sanction was combined. The court ordered, “as a sanction,” that counsel pay all costs and fees the defendant incurred in defending the lawsuit and that the case be dismissed with prejudice once payment is finalized, and it directed counsel to send the order to the Illinois ARDC. The Central District of Illinois later relied on this history in Cole v. Hobby Town Unlimited, and counsel’s filing in Hippe v. Retention Brands is part of the same pattern that court described. Firms documenting compliance may wish to consider that, here, the AI-citation finding did not stand alone: the court weighed it with other conduct, and the consequence fell on the client’s case as well as on counsel.