Shelton v. Parkland Health
U.S. District Court, Northern District of Texas · N.D. Tex. · Texas bar guidance
Verified May 5, 2026
- Citation
- Shelton v. Parkland Health, No. 3:24-cv-02190 (N.D. Tex. Nov. 10, 2025)
- Decided
- November 10, 2025
Summary
Plaintiff's counsel Jennifer Davidson filed a summary judgment brief containing multiple citations to cases that either did not exist or did not support the propositions for which they were cited. After defense counsel for Parkland Health flagged the errors and pointed Davidson to the Northern District of Texas judges' local rule requiring disclosure of generative AI use, Davidson refiled what was largely the same brief without correcting the citations or making the required disclosure. Davidson conceded she had delegated the research and drafting to another person (an attorney or law student intern) and had not personally verified the citations before filing. Judge Sam A. Lindsay found the conduct sanctionable but accepted that Davidson had not made affirmative misrepresentations.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Judge Lindsay admonished Davidson for filing a brief containing fabricated and unsupported AI-generated citations and for failing to comply with the court's local disclosure rule on generative AI. No monetary sanction was imposed.
Why does Shelton v. Parkland Health matter for law firms using AI?
Shelton illustrates two failure modes that compound risk for small and mid-size firms: delegating research to a junior without a verification checkpoint, and missing a court-specific GAI disclosure rule. Northern District of Texas judges have adopted standing orders and local rules on generative AI that vary by chambers, and a managing partner relying on a firm-wide “we don’t use AI” policy may still face sanctions when an associate or contract researcher does. The court’s willingness here to admonish without a monetary fine should not be read as leniency that will repeat: later 2025 and 2026 orders in the same district have escalated to dollar sanctions on similar facts.
Sources
Primary sources
Further reading
- Justia (legal 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.