Raymond Alan Shields v. First Financial Corporation
Sixth Circuit Court for Davidson County, Tennessee · Tenn. Cir. Ct. (Davidson Cnty.) · Tennessee bar guidance
Verified September 29, 2026
- Citation
- Shields v. First Financial Corp., No. 25C1446 (Tenn. Cir. Ct., Davidson Cnty. Nov. 21, 2025) (Brothers, J.)
- Decided
- November 21, 2025
Summary
In an order granting Plaintiff's Motion to Amend Complaint, Judge Thomas W. Brothers cautioned Plaintiff's counsel about six incorrect citations spread across her Motion for Limited Discovery, Response to Defendant's Motion to Compel, and Motion to Amend. The defects included a nonexistent Doe v. Roe Tennessee Court of Appeals decision (the docket number actually returned Jones v. Jones), a Nandigam Neurology citation pairing a real case with a Westlaw number and docket number that returned no Tennessee case, a citation to "Tenn. R. Civ. P. 6(a)(1)" that does not exist, and citations to Doe v. Roe, Schultz v. Davis and Vincent v. Yelverton, which the order says do not exist, with reporter numbers that it says correspond to Texas, Missouri and Sixth Circuit decisions in other cases. The court wrote that "[t]hese manners of incorrect citations are characteristic of Artificial Intelligence use in the research of law. Whether Plaintiff's Counsel used AI or not in the drafting of her filings, the Court would like to caution her to verify that any citations to law are correct both in reference and content."
- AI tool:
- Not determined (the order says the errors are "characteristic of Artificial Intelligence use" and does not find that AI was used)
What did the court warn about?
No sanction. The written order grants the Motion to Amend and cautions Plaintiff's counsel to verify that any citations to law "are correct both in reference and content."
Why does Raymond Alan Shields v. First Financial Corporation matter for law firms using AI?
Shields shows a light judicial response: an order granting the motion it decided, followed by a list of six incorrect citations and a caution to counsel. The court did not find that AI was used. It said the errors were “characteristic of Artificial Intelligence use in the research of law” and that, whether or not counsel used AI, counsel should verify citations “both in reference and content.” The order does not name counsel, but it identifies each faulty citation and the filing and page where it appeared.
Sources
Further reading
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.
- The order does not name Plaintiff's counsel; it refers only to "Plaintiff's Counsel."
- The cited copy is a third-party tracker's mirror of the order (e-filed 11/21/25, Case No. 25C1446). No court-hosted copy is reachable: Davidson County Circuit Court Clerk documents are available only through the paid CaseLink subscription.