AI-related case
Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (2)
The Court found that attorney Tyrone A. Blackburn repeatedly used quotation marks for language that does not appear in the cases he cited (including at least 17 instances) and defended that practice as paraphrase. Opposing counsel (Roc Nation) flagged these apparent AI-generated citation errors, and the Court independently verified the quotations. Citing prior orders and sanctions (including a $5,000 sanction in Jakes v. Youngblood), the Court concluded Blackburn's conduct evidenced a pattern of fabricating quotations, granted the motion to strike his filing, deemed the sanctions motion unopposed, and referred Blackburn to the Grievance Committee. The Court emphasized the obligation to accurately quote and cite authority and noted refusal to accept paraphrases presented as verbatim quotations.
Judges: Jennifer E. Willis