United States v. Karnezis

What did the court warn about?

The court wrote: "This Court admonishes Williams's counsel for misquoting Smith[.]" In the accompanying footnote it added: "This Court reminds Williams's counsel that he is responsible for not only his own contributions but also his client's contributions to any of his submissions." No monetary or other sanction was imposed and no referral was made. On the merits, the court granted the motion to suppress in part and denied it in part: it suppressed Williams's statements after page 77 of the interview transcript in response to questions about his bank accounts (a selective invocation) and all statements after page 168, where he asked, "Can I call my attorney?" The remaining statements were not suppressed, the request to suppress derivative evidence was rejected, and the court found no evidentiary hearing warranted. The government was ordered to provide a redacted interview transcript. The companion motion to compel was addressed in a separate opinion.

Why does United States v. Karnezis matter for law firms using AI?

Karnezis is a criminal suppression ruling in which a single bad quotation drew a written admonishment. Williams argued that agents violated his right to counsel when one of them interrupted him mid-sentence, and his reply attributed to Smith v. Endell a holding that officers “cannot ‘prevent a suspect from making an unambiguous request for counsel by cutting him off.’” Judge Immergut found that the words Williams actually spoke never mentioned an attorney, and that Williams, “[p]erhaps recognizing that Smith does not support his argument,” had resorted “to providing a non-existent quotation from the case.” The court then admonished counsel for misquoting Smith, while also stating that it did not endorse the agent’s interruption.

The AI question was raised and left unresolved. According to the footnote, counsel stated at the hearing that the error “was not a result of using generative AI but rather an inadvertent mistake.” The court did not reject that explanation or make any finding about how the quotation arose. It instead reminded counsel that “he is responsible for not only his own contributions but also his client’s contributions to any of his submissions,” a sentence that places responsibility for a client’s contributions on counsel.

The admonishment did not affect the merits. The court suppressed Williams’s answers about his bank accounts after a selective invocation and all statements after a later invocation, and denied suppression of the rest. For firms, the order is a reminder that the explanation offered for a non-existent quotation (AI, inadvertence, or a client’s contribution) does not change who is answerable for it.