United States v. Czartorski
U.S. District Court, Western District of Kentucky, Louisville Division · W.D. Ky. · Kentucky bar guidance
Verified April 26, 2026
- Citation
- United States v. Czartorski, No. 3:25-cr-00030-RGJ (W.D. Ky. Nov. 10, 2025) (Memorandum Opinion & Order, DE 73)
- Decided
- November 10, 2025
Summary
Defendant James Cameron Wright's motion to sever, filed in a federal civil-rights prosecution of three Kentucky State Police troopers, cited multiple fictitious federal opinions, including United States v. Hang Le-Thy Tran, No. 3:07-CR-53, 2008 WL 2699394 (E.D. Ky. July 3, 2008); United States v. Cope, 312 F. Supp. 2d 791 (E.D. Ky. 2004); and United States v. Abbott, 2023 WL 4106534 (E.D. Ky. June 27, 2023). The brief also misrepresented the holdings of real Sixth Circuit cases (Chavis and Tran). Co-defendant Lewis flagged the fabrications in his own filing, noting the Westlaw citation "did not yield any results" and the Abbott decision date predated the actual Abbott case. Judge Rebecca Grady Jennings presumed the errors arose from reliance on AI-generated content.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court ordered Wright's counsel to appear on November 18, 2025 to show cause why they should not be sanctioned under Federal Rule of Civil Procedure 11(b)(2) and (c) and the court's inherent power for citing fictitious decisions and misrepresenting the holdings of real cases in reliance on AI-generated content. No monetary sanction had been imposed as of the order date.
Why does United States v. Czartorski matter for law firms using AI?
The Czartorski show-cause order is notable because the fabricated citations appeared in a criminal defense filing on behalf of a federal civil-rights defendant, raising the stakes of an AI-citation lapse beyond civil malpractice exposure. The court also flagged a more insidious failure mode: citations to real Sixth Circuit cases whose holdings were misrepresented, which the judge noted are harder to detect than wholly fabricated cases because a recognizable case name suppresses scrutiny. Firms with criminal-defense practices should treat this order as direct notice that Rule 11 (and inherent-power) sanctions reach AI-assisted briefs in criminal matters within the Western District of Kentucky.
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.
- AI tool identity: the order does not name a specific tool (e.g., ChatGPT). The court refers only to 'AI-generated content.'