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
Verified May 14, 2026
- Citation
- Warfield v. W.N. Morehouse Truck Line, Inc., No. 2:25-cv-00037-DCLC-CRW, 2025 WL 3102069 (E.D. Tenn. Nov. 6, 2025) (Corker, J.)
- Decided
- November 6, 2025
Summary
In a Title VII and FLSA action filed by plaintiff Jamison Warfield against his former employer, plaintiff's counsel William A. Wooten (Wooten Law Office, Covington, TN) filed a response to a Rule 12(b)(2) motion to dismiss that relied on "incorrect and nonexistent case citations," as flagged by defendant Morehouse in its reply brief. The court (Judge Clifton L. Corker) noted the defective citations in passing and dismissed the complaint without prejudice for lack of personal jurisdiction, holding that although Morehouse purposefully availed itself of Tennessee through brokered hauls and by hiring a Tennessee-resident driver, none of the alleged discriminatory or retaliatory conduct arose out of or related to those Tennessee contacts. The order does not name a generative AI tool and does not impose a Rule 11 sanction or order a show cause; the AI hallmark is the bare fact that cited authorities did not exist.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Complaint dismissed without prejudice for lack of personal jurisdiction. The court flagged the nonexistent citations in plaintiff's response brief but imposed no monetary sanction, no CLE requirement, and no disciplinary referral in this order.
Why does Jamison Warfield v. W.N. Morehouse Truck Line, Inc. matter for law firms using AI?
Warfield is a useful contrast to the Mata-style hallucination cases: the court flagged plaintiff’s brief as containing “incorrect and nonexistent case citations” but treated that as background to a routine personal-jurisdiction dismissal rather than as grounds for Rule 11 proceedings. For a managing partner, the cautionary note is that defective citations now turn up regularly enough in opposing briefs that judges describe them in a single sentence and move on, which means a firm’s reputational exposure does not require a published sanctions order: it can come from being the cited example in the next motion-to-dismiss reply brief, or in a footnote of a routine opinion that is then indexed by every legal-research tool.
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.
- No CourtListener docket URL was located during verification; only the Westlaw citation (2025 WL 3102069) and the verbatim PDF were available.
- Whether a separate show-cause or sanctions proceeding has been or will be opened in the docket is not addressed in this order.