June 1, 2026 (in 3 days): New York: 22 NYCRR Part 161 takes effect, system-wide AI policy for all UCS courts

Vita Law Offices, P.C. v. Lockridge Grindal Nauen P.L.L.P.

U.S. District Court, District of Massachusetts · D. Mass. · Massachusetts bar guidance

Court sanction

Verified April 26, 2026

Citation
Vita Law Offices, P.C. v. Lockridge Grindal Nauen P.L.L.P., No. 1:25-cv-11155 (D. Mass. July 23, 2025)
Decided
July 23, 2025

Summary

Attorney Christopher Cervantes of Cervantes Law, P.C., representing plaintiff Vita Law Offices in a referral-fee dispute against Lockridge Grindal Nauen, filed a brief containing fabricated case quotations generated by Microsoft Copilot. Among the invented passages was a quotation attributed to Carden v. Arkoma Associates, 494 U.S. 185 (1990), purportedly addressing diversity jurisdiction. Judge Brian E. Murphy issued an order to show cause after identifying multiple fabricated quotes, and Cervantes acknowledged that he had used Copilot without verifying its output against the underlying authorities.

AI tool:
Microsoft Copilot
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

No monetary penalty. Judge Murphy resolved the matter on the condition that Cervantes complete four continuing legal education courses within 60 days, covering the use of AI in legal practice, legal ethics, and federal practice.

Why does Vita Law Offices, P.C. v. Lockridge Grindal Nauen P.L.L.P. matter for law firms using AI?

Vita v. Lockridge is notable because the court accepted a tailored remedial CLE package in lieu of monetary sanctions, signaling that judges may treat candid first-time Copilot misuse as a competence and supervision failure rather than bad faith. For managing partners, the case underscores that even integrated office-suite AI tools sit squarely within Rule 1.1 verification duties.

Sources

Primary sources

Further reading