Young v. Daniel Boone Area School District
U.S. District Court, Eastern District of Pennsylvania · E.D. Pa. · Pennsylvania bar guidance
Conduct
Judge Leeson sua sponte issued a Certificate of Use of Generative AI requirement for all filings in this case.
Consequence
No sanctions imposed; forward-looking case-specific disclosure-and-certification regime applicable for case duration.
Lesson
E.D. Pa. case-specific order using the M.D. Pa. Certificate of Use of Generative AI template later generalized chambers-wide.
Verified May 8, 2026
- Citation
- Young v. Daniel Boone Area Sch. Dist., No. 5:24-cv-04729 (E.D. Pa. Sept. 10, 2024) (Leeson, J.)
- Decided
- September 10, 2024
Summary
Judge Joseph F. Leeson Jr. issued an Initial Procedural Order in Young v. Daniel Boone Area School District requiring that any party using generative AI tools in connection with court filings file a Certificate of Use of Generative AI. The order is case-specific (not a chambers-wide standing order) but adopts substantively the same certificate template the M.D. Pa. judges (Mehalchick, Latella, Caraballo) later generalized as chambers-wide rules. The Eastern District of Pennsylvania has the Joint Formal Opinion 2024-200 from the Pennsylvania Bar and Philadelphia Bar Associations as the background ethical guidance the order cross-references.
- AI tool:
- Generative AI generally (the order references concerns about generative AI generating 'legally or factually incorrect information' and 'unsupported or nonexistent legal citations')
What sanction did the court impose?
Initial Procedural Order entered with no sanctions imposed. The order operates as a forward-looking disclosure-and-certification requirement applicable for the duration of the case.
Why does Young v. Daniel Boone Area School District matter for law firms using AI?
Young v. Daniel Boone Area School District is the Eastern District of Pennsylvania’s earliest case-specific procedural order requiring AI use disclosure and citation verification. Judge Leeson’s Initial Procedural Order (September 10, 2024) imported the Certificate of Use of Generative AI template that Judge Mehalchick had introduced two weeks earlier in M.D. Pa. (E.J. v. Johnson, August 19, 2024) and that subsequently became the chambers-standing template across the M.D. Pa. magistrate-judge cluster (Latella, Caraballo) plus Mehalchick herself.
The order is case-specific rather than chambers-wide; it applies to the Young matter but does not bind other proceedings before Judge Leeson. The substantive requirements are the same: any party using generative AI must file a Certificate disclosing the specific tool, identifying the AI-drafted portions, and certifying human review of all citations and legal authority. Failure to comply may result in sanctions.
For E.D. Pa. practitioners, the order is useful authority for the proposition that federal judges in this district may issue case-specific AI procedural orders sua sponte in the early stages of any matter, even where the judge has no published chambers standing rule. Firms appearing before E.D. Pa. judges without published AI rules should expect that such orders may issue and should be prepared with disclosure-and-certification language pre-built into their PA federal-court briefing templates.
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.
- Cite Young v. Daniel Boone for the proposition that E.D. Pa. judges may issue case-specific AI procedural orders even where their chambers does not have a standing AI rule. Firms with E.D. Pa. matters before judges without published chambers AI rules should expect such orders to issue early in the case lifecycle.
- The Certificate of Use of Generative AI template (used here and in M.D. Pa. chambers cluster) is now the dominant Pennsylvania federal-court framework. Firms should standardize their disclosure-and-certification process around this template for any PA federal matter.
Sources
Further reading
- Court-side primary source URL on paed.uscourts.gov for this specific docket order has not been located. R&G hosts a PDF mirror at the secondary URL above. PACER docket 5:24-cv-04729 is the underlying primary record; CourtListener docket search is included as the primary-source-tier URL.