Ringer v. Bank of America, N.A.
U.S. District Court, Northern District of Georgia, Atlanta Division · N.D. Ga. · Georgia bar guidance
Verified April 26, 2026
- Citation
- Ringer v. Bank of America, N.A., No. 1:25-cv-3959-SEG-JSA, 2025 WL 3765431 (N.D. Ga. Dec. 30, 2025)
- Decided
- December 30, 2025
Summary
Defendant's counsel Danny Patterson Jr. of McGuireWoods LLP submitted a Memorandum of Law in support of a motion to dismiss containing numerous miscited cases and inaccurate verbatim quotations, including a lengthy purported block quotation from a statute that was almost entirely paraphrased. Magistrate Judge Justin S. Anand issued an Order to Show Cause; Patterson admitted all citation and quotation errors but denied using ChatGPT or any AI tool, attributing the errors to careless transposition of manual research notes. District Judge Sarah E. Geraghty adopted the magistrate's Report and Recommendation and imposed Rule 11 sanctions.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,500
What sanction did the court impose?
$1,500 payable to the registry of the Court within 21 days, public naming of attorney and firm with publication in the official case reporter, and a requirement that supervisory counsel co-sign all future papers and a paralegal cite-check all submissions. The Court separately ordered McGuireWoods LLP to submit a sworn statement describing its training, oversight, procedures, and resources for ensuring citation accuracy; managing partner J. Tracy Walker IV filed the declaration and the Court accepted the firm's response.
Why does Ringer v. Bank of America, N.A. matter for law firms using AI?
Ringer is notable less for the modest $1,500 fine than for what the court ordered alongside it: a large law firm was directed to submit a sworn statement on its training, oversight, and cite-checking procedures, even after the individual attorney denied any AI use. Magistrate Judge Anand framed the sanction explicitly in terms of general deterrence “in the age of artificial intelligence,” reasoning that careless citation errors must be treated more seriously regardless of whether AI was the proximate cause. For managing partners, the order is a marker that federal courts now expect firms, not just individual lawyers, to document the supervisory infrastructure behind every filing.
Sources
Further reading
- CourtListener docket search (aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
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.
- Whether generative AI was actually used; the sanctioned attorney denied AI use under oath, and the magistrate judge credited that denial while noting the errors 'could have been generated by AI' and were 'consistent with' careless manual paraphrasing.