Raymond Alan Shields v. First Financial Corporation
Sixth Circuit Court for Davidson County, Tennessee · Tenn. Cir. Ct. (Davidson Cnty.) · Tennessee bar guidance
Verified April 26, 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 that returned no Tennessee case, a citation to "Tenn. R. Civ. P. 6(a)(1)" that does not exist, and reporter citations for Doe v. Roe and Schultz v. Davis whose volume and page numbers actually corresponded to Texas and Missouri appellate decisions. The court observed these "manners of incorrect citations are characteristic of Artificial Intelligence use in the research of law" and, without finding that AI was in fact used, cautioned counsel to verify all citations going forward.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. The court issued an on-the-record caution to Plaintiff's counsel to verify that any citations are correct in both reference and content, while still granting the underlying Motion to Amend.
Why does Raymond Alan Shields v. First Financial Corporation matter for law firms using AI?
Shields is a useful example of the “soft” judicial response now emerging in state trial courts: a published order that names every defective citation, attributes the pattern to characteristic AI hallucination signatures, and declines to sanction while putting counsel and the bar on notice. For a managing partner, the lesson is that a no-monetary outcome still produces a public, search-indexed order tying counsel’s name to AI-style citation failures, which is a malpractice and reputational exposure even where Rule 11 or its state analog is not invoked.
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 to her only as "Plaintiff's Counsel" and uses feminine pronouns. The certificate of service lists three pro se recipients (Kimberly Cross Shields, Brittany Gates, Sarah Martin) but the filing attorney is not identified within the four corners of this order.