Russel Williams Home Services LLC v. Minleon International (USA) Limited LLC
U.S. District Court, Middle District of Pennsylvania · M.D. Pa. · Pennsylvania bar guidance
Verified May 14, 2026
- Citation
- Russel Williams Home Servs. LLC v. Minleon Int'l (USA) Ltd. LLC, No. 1:25-cv-01665 (M.D. Pa. Dec. 17, 2025) (Neary, J.)
- Decided
- December 17, 2025
Summary
The court issued an Order to Show Cause after identifying apparently AI-generated content in a brief filed in the matter, including a fabricated quotation attributed to Abbott Laboratories v. Sandoz that does not appear in that decision. The order directs counsel to explain the false citation and address whether sanctions are warranted under Rule 11 and the court's inherent authority.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to Show Cause entered on December 17, 2025 requiring counsel to respond and explain the fabricated authority. No monetary sanction or discipline imposed at the order-to-show-cause stage.
Why does Russel Williams Home Services LLC v. Minleon International (USA) Limited LLC matter for law firms using AI?
For managing partners, this M.D. Pa. order is another reminder that fabricated quotations, not just fake case names, now trigger show-cause practice. A bogus quote attributed to a real decision (here, Abbott Laboratories v. Sandoz) is the harder failure mode to catch in review because the cited case exists and the cite-checker’s first pass may pass it. Firm AI-use policies should require pulling and verifying the underlying language for any quoted authority, not merely confirming the case is real.
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.
- Counsel of record for Minleon (the attorneys ordered to show cause) is not named in the four corners of the December 17, 2025 order; the order refers to "counsel for Minleon" without identifying the individual filer.