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New Jersey lawyer faces contempt over unpaid AI sanctions in Diddy case

Published
Score
11

Why it matters

Tyrone Blackburn, the attorney representing Liza Gardner in a sexual assault civil suit against Sean "Diddy" Combs, faces a contempt hearing in New Jersey federal court over unpaid sanctions tied to AI-generated case citations. U.S. District Judge Noel L. Hillman ordered Blackburn to pay $6,000 in December 2025—$500 monthly—after finding that a brief he filed contained a fabricated case opinion produced by an artificial intelligence research tool. The case cited did not exist.

Blackburn has missed at least some of the monthly payments, triggering the contempt-show-cause order requiring him to appear before the court in 2026. The specific details of which payments remain outstanding are not yet public.

The case signals a shift in judicial enforcement. Courts are moving beyond monetary sanctions toward contempt proceedings when attorneys fail to pay for or correct AI-related misconduct. Judges increasingly treat misuse of AI in legal research as a serious breach of professional responsibility, particularly where attorneys ignore sanctions orders or continue to misrepresent case law. Attorneys relying on AI research tools should expect courts to treat noncompliance with sanctions orders as grounds for contempt rather than as a cost of doing business.

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