Smith v. Trump
U.S. District Court, District of Columbia · D.D.C. · District of Columbia bar guidance
Verified April 26, 2026
- Citation
- Smith v. Trump, No. 21-cv-02265 (APM), ECF No. 442 (D.D.C. Oct. 16, 2025) (order to show cause)
- Decided
- October 16, 2025
Summary
Carolyn A. Stewart, counsel for defendant Kelly Meggs in the January 6 civil suit brought by Capitol Police officers against Donald J. Trump and others, filed an opposition to plaintiffs' motion to compel that was rife with fabricated citations to nonexistent D.D.C. Local Civil Rules, including "Civil Procedure Rule 104 (7)-(8)," "D.D.C. local Rule 104(7)," "D.D.C. Rule 8(a)," "Court's Rule 8(a)," and "L.R. 104.8," along with fabricated block quotations purporting to recite the text of those nonexistent rules. After plaintiffs flagged the false citations in their reply, Stewart acknowledged only that she had meant to cite a Maryland local rule and did not correct the remaining fabrications. Judge Amit P. Mehta issued an order to show cause why sanctions should not be imposed and a referral made to bar authorities under Model Rule 3.3(a)(1) and the parallel D.C. and Florida rules.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause issued October 16, 2025, with a response due October 21, 2025. Stewart was directed to explain how the fabricated Local Civil Rule citations and block quotations came to be included in the opposition and why she did not take immediate steps to withdraw or fully correct the filing once the false citations were flagged. The order expressly contemplates sanctions and a referral to relevant bar authorities.
Why does Smith v. Trump matter for law firms using AI?
Smith v. Trump is a high-profile civil suit by U.S. Capitol Police officers against the former president and others arising from January 6, 2021. The order to show cause is notable because the fabrications were not phantom case citations of the Mata v. Avianca pattern, but invented Local Civil Rules of the very court hearing the case, complete with fabricated block quotations of rule text. For managing partners, the case underscores that generative-AI fabrications extend beyond caselaw to procedural rules a court can verify on its own docket within seconds, and that a partial, late correction does not cure a Rule 3.3 candor problem.
Sources
Primary 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.