Wilson v. KIPP Texas, Inc.
U.S. District Court for the Northern District of Texas, Dallas Division · N.D. Tex. · Texas bar guidance
Verified April 24, 2026
- Citation
- Wilson v. KIPP Texas, Inc., No. 3:24-cv-02578-K (N.D. Tex. Oct. 29, 2025) (Kinkeade, J.)
- Decided
- October 29, 2025
Summary
In opposing defendant's motion for summary judgment, plaintiff's counsel used ChatGPT to compare two job descriptions (Senior Director, Academic Recovery and Senior Director of Academic Acceleration) and inserted the resulting output as verbatim 'quotations' into plaintiff Dr. Joy Wilson's sworn declaration. In all, counsel used ChatGPT to generate 11 non-existent statements attributed to job-description language. Counsel failed to include the AI disclosure required by N.D. Tex. Local Civil Rule 7.2(f) on the first page of the summary judgment response, which under Rule 7.2(f)(3) affirmatively certified that no part of the brief was prepared with generative AI. Defendant identified the inaccuracies in its reply, and counsel then filed an AI Notice acknowledging the use.
- AI tool:
- ChatGPT
What sanction did the court impose?
Judge Ed Kinkeade found counsel violated Local Civil Rule 7.2 and Federal Rule of Civil Procedure 11(b)(3) by submitting factual contentions that lacked evidentiary support. The Court imposed the violation solely on counsel, not on the plaintiff. Sanctions ordered: (1) counsel must reimburse defendant for attorney's fees and associated costs incurred in preparing the summary judgment reply, with the amount to be determined by conferral within 7 days and reported to the court; (2) counsel must attend 2 hours of CLE on artificial intelligence, in person or online, within 4 months, and file a sworn certification of completion. Defendant's separate motion to strike the argument portion of the AI Notice was denied. Plaintiff was granted leave on the court's own motion to file an amended summary judgment response and appendix, omitting all artificially generated information, by November 7, 2025.
Why does Wilson v. KIPP Texas, Inc. matter for law firms using AI?
Wilson v. KIPP Texas is the first confirmed enforcement of the Northern District of Texas’s mandatory generative AI disclosure rule, Local Civil Rule 7.2(f). It is doctrinally notable on two fronts. First, the court treated the failure to include the required first-page AI disclosure as an affirmative false certification under Rule 7.2(f)(3), independent of the accuracy problem, reasoning that the rule’s default presumption is that no AI was used unless disclosed. Second, the court tailored the sanction to the specific conduct (insertion of fabricated verbatim quotations into a sworn declaration) without imposing a flat fine: the fees-based reimbursement measures the actual cost to the opposing party, and the CLE requirement is designed to change the behavior going forward. For attorneys practicing in the Northern District, Wilson establishes that disclosure is a bright line: disclose AI use on the first page of any brief, or face sanctions regardless of whether the underlying substance is otherwise defensible.