Rivera v. Triad Properties Corporation
U.S. District Court, Northern District of Alabama · N.D. Ala. · Alabama bar guidance
Verified April 26, 2026
- Citation
- Rivera v. Triad Properties Corp., No. 2:24-cv-01802-AMM (N.D. Ala. Mar. 31, 2026)
- Decided
- March 31, 2026
Summary
Attorney Joshua B. Watkins of Burrill Watkins LLC filed a response to a motion to dismiss containing hallucinated and misrepresented citations generated by ChatGPT, including a misattribution of S.E.C. v. Digital Lightwave to the District of Utah when the case was decided in the Middle District of Florida and did not support the proposition cited. After the fabrications were exposed, Watkins repeatedly shifted blame, made misrepresentations to the court, failed to keep his clients informed of the disciplinary proceedings, and a forensic examination later found his ChatGPT history had been deleted in a manner consistent with intentional erasure. Judge Anna M. Manasco found that fines alone were insufficient given the post-misconduct deception and imposed a layered sanction.
- AI tool:
- ChatGPT
- Sanction amount:
- $47,056.90
What sanction did the court impose?
Public reprimand of Watkins and Burrill Watkins LLC, three-month suspension of Watkins from practice in N.D. Ala., disqualification of Watkins and the firm from the case, referral to the Alabama State Bar, publication of the order in the Federal Supplement, and attorney's fees totaling $47,056.90 ($11,453 to the Triad Defendants from Burrill Watkins; $35,603.90 to the Fite Defendants jointly and severally from Watkins and the firm).
Why does Rivera v. Triad Properties Corporation matter for law firms using AI?
Rivera is a notable escalation beyond Mata: the court explicitly found that monetary sanctions and public embarrassment alone were inadequate deterrents, and added suspension, firm-level disqualification, and bar referral. The opinion targets the firm as well as the individual attorney, finding that Burrill Watkins paid for ChatGPT access and encouraged its use without “internal policies or controls or guardrails” to prevent abuse. For firms documenting AI governance during malpractice renewal, the order is a direct articulation of what an “absence of controls” looks like to a federal court.