Shore v. Dorel Juvenile Group, Inc.

What sanction did the court impose?

In its May 12, 2026 Order Imposing Sanctions, Judge Leo T. Sorokin found that all of the attorneys failed to act prudently when the reply flagged the quotations, and that "[b]ecause the AI-based errors in the brief were pervasive," the opposition should be struck; plaintiffs could file a revised opposition by May 19, 2026. It held that Laukaitis Law "bears primary responsibility," ordered it to file a status report within 21 days on whether it had implemented four suggested remedial measures (which the court encouraged but did not require), and ordered Laukaitis "to pay $2,500 to Defendant in light of the time and resources wasted by the Court and counsel on this avoidable problem and to effectively deter similar misconduct." It imposed nothing further on Siri & Glimstad or Poulin | Willey | Anastopoulo, found that "no further consequences, sanctions, or referrals are warranted because of the forthcoming and candid (if belated) responses of counsel," and discharged the order to show cause. The order names no rule as the basis for the $2,500 payment; its discussion cites Model Rule of Professional Conduct 3.3(a)(1) and, with a "cf." signal, Federal Rule of Civil Procedure 11(b)(2) (slip op. at 4, 6).

Why does Shore v. Dorel Juvenile Group, Inc. matter for law firms using AI?

Shore v. Dorel is a detailed account of how an AI error moved through a three-firm drafting process. The sections were written without AI, but the lawyer who compiled the brief used ChatGPT and Claude to improve its style, and the tools rewrote quotations. He did not check the changes or tell co-counsel; a second firm confirmed that the cited cases existed but not what they said; and the third firm did not see the final draft before it was submitted. When the defendant’s reply flagged two quotations, no one responded for nearly six months.

Judge Sorokin addressed the case as a failure common to all counsel and then firm by firm. All of the attorneys should have checked the flagged quotations and alerted the court. Because the AI-based errors were pervasive, the brief was struck, with leave to refile because the errors were traceable to the lawyers and not their clients. The firm with “primary responsibility” was ordered to report on remedial procedures and its attorney to pay $2,500 to the defendant; the other two firms received no sanctions. The court credited the candor of counsel’s response to the show-cause order as the reason no further sanctions or referrals were warranted.

Firms documenting compliance may wish to consider the four measures the court suggested but declined to require: disclosing an AI-use policy to co-counsel, disclosing AI use on jointly filed briefs, sharing redlines of changes, and independently verifying every quotation, citation and proposition before filing AI-assisted work.