Jamison Warfield v. W.N. Morehouse Truck Line, Inc.
U.S. District Court, Eastern District of Tennessee, Northeastern Division · E.D. Tenn. · Tennessee bar guidance
Conduct
Here the defendant's reply asserted that the plaintiff's response relied on incorrect and nonexistent case citations; the court only summarized that assertion.
Consequence
No sanction or warning. The court dismissed the complaint without prejudice for lack of personal jurisdiction.
Lesson
Here an opponent's reply put the citation problem on the record, and the court repeated it in one sentence of its opinion.
Verified September 29, 2026
- Citation
- Warfield v. W.N. Morehouse Truck Line, Inc., No. 2:25-cv-00037-DCLC-CRW, Memorandum Opinion and Order (E.D. Tenn. Nov. 6, 2025) (Corker, J.), ECF No. 21
- Decided
- November 6, 2025
Summary
Jamison Warfield sued his former employer, Nebraska-based W.N. Morehouse Truck Line, Inc., under Title VII and the Fair Labor Standards Act. Morehouse moved to dismiss for lack of personal jurisdiction and improper venue. In summarizing the briefing, District Judge Clifton L. Corker wrote one sentence on the citation issue: "In reply, Morehouse notes that Warfield relied on incorrect and nonexistent case citations." The court did not examine the citations, make any finding about them, or return to the subject. It resolved the motion on personal jurisdiction alone: Morehouse had purposefully availed itself of Tennessee by hiring a Tennessee resident and hauling loads into and out of the state, but Warfield's discrimination, retaliation, and wage claims did not arise out of or relate to those contacts, because the conduct he alleges occurred outside Tennessee. The order does not identify Warfield's counsel and does not mention artificial intelligence.
- AI tool:
- Unidentified (the order only recounts the defendant's assertion of incorrect and nonexistent citations; it does not mention AI or name a tool)
- Amount or terms:
- None
How did the court address the AI-related conduct?
Complaint dismissed without prejudice for lack of personal jurisdiction, with a separate judgment to follow. The order imposes no sanction, issues no warning, and orders no show-cause proceeding; its only reference to the citations is its summary of Morehouse's reply brief. The court did not reach the third, reasonableness element of the Sixth Circuit's Mohasco test.
Why does Jamison Warfield v. W.N. Morehouse Truck Line, Inc. matter for law firms using AI?
Warfield belongs in the tracker because an aggregator lists it, but the order says very little about citations. In its summary of the briefing, the court recounts that “Morehouse notes that Warfield relied on incorrect and nonexistent case citations,” citing pages 1 and 2 of Morehouse’s reply. The court does not identify the citations, does not say whether it agreed, and does not mention artificial intelligence, Rule 11, or any possible sanction. Everything else in the opinion’s analysis concerns personal jurisdiction.
On that question, the court found purposeful availment satisfied: Morehouse hired Warfield knowing he lived in Tennessee, assigned him a truck to use from his Tennessee home base, arranged his drug screening near his home, and earned revenue hauling loads into and out of the state. But the claims failed the “arise out of or relate to” element: Morehouse’s employment decisions were made in Nebraska, the events leading to the arrest took place in Iowa, and “all the conduct underlying Warfield’s claims occurred outside of Tennessee.” The court dismissed without prejudice.
Firms documenting compliance may wish to consider that an opponent’s allegation about defective citations can be repeated in a court’s written summary of the briefing even when the court never decides the point.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify citations in opposition briefs as carefully as in opening briefs. Here the defendant's reply called out the plaintiff's citations as incorrect and nonexistent, and the court repeated that assertion without deciding it.
- Review how an opponent's accusation can reach the court's opinion. This court repeated Morehouse's assertion in its background summary without deciding whether it was true.
Sources
Primary sources
- AI attribution is a Charlotin tracker inference: the order does not mention artificial intelligence, and it reports the incorrect and nonexistent citations only as Morehouse's assertion in its reply (Doc. 15), not as a finding of the court.
- The order does not identify who drafted or signed Warfield's response (Doc. 14). A Westlaw counsel header lists William A. Wooten for the plaintiff; that header is not part of the court's text and was not verified against the docket.
- Whether any later show-cause or sanctions proceeding occurred on the docket is not addressed in this order.