A September 2026 order by U.S. District Judge Angel Kelley found that the attorney relied on "inaccurate and fictitious" citations generated by artificial intelligence in an insurance coverage dispute. Kelley removed him from the case and directed him to pay the opposing side's legal fees, capped at $10,000. The judge also criticized "our collective character" in light of repeated cases of attorneys filing AI-drafted documents without verifying them. The November report does not identify that case, so the reporting does not connect it to the September order.
The ruling matters because the sanctions are now being tested on reconsideration, and the judge kept them in place. Attorneys should verify every citation in AI-assisted filings against the original source before filing, and treat that check as a professional obligation. Massachusetts courts have been acting on this since at least February 2024, when Associate Justice Brian A. Davis of the Superior Court sanctioned a lawyer $2,000 for fake citations produced by an AI tool. In September 2025, the California Court of Appeal issued the state's first published opinion on AI-fabricated citations and sanctioned the responsible attorney $10,000.