IV. Key Facts 1) A response opposing summary judgment cited two non-existent cases and included quotations that could not be located in the cited authorities. 2) Counsel admitted he used Claude to generate the response and failed to verify the citations and quotations. 3) After a show-cause order and hearing, the court found the conduct warranted deterrent sanctions. JAMES GAUTHIER, Plaintiff, v. GOODYEAR TIRE & RUBBER CO., Defendant. United States District Court, E.D. Texas. November 25, 2024. MARCIA A. CRONE, District Judge. MEMORANDUM AND ORDER A Texas attorney faces sanctions for using case cites that refer to nonexistent cases and quotations also made up by generative AI. Goodyear Tire & Rubber Co. matter for law firms using AI? Gauthier is the second documented sanctions order naming Anthropic’s Claude as the source of fabricated citations, and an early example of a court treating a vendor-marketed legal AI verification feature, here a Lexis AI tool, as no substitute for the attorney’s own duty to confirm. Gauthier v. Goodyear Tire & Rubber Co., No. 1:2023cv00281 - Document 53 (E.D. Tex. 2024) case opinion from the Eastern District of Texas U.S. Federal District Court EASTERN DISTRICT OF TEXAS JAMES GAUTHIER, Plaintiff, versus GOODYEAR TIRE & RUBBER CO., Defendant. In Gauthier v. Goodyear Tire & Rubber Co., a lawyer was sanctioned for submitting unverified GAI-generated content in a response to a motion for summary judgment. No. 1:23-CV-281 (E.D. Tex. Nov. 25, 2024). This included two citations to entirely fabricated cases and nonexistent quotations from seven actual cases—that is, “hallucinations.” On November 7, 2024, the court entered an order directing Monk to show cause why the court should not impose sanctions for his failure to comply with Federal Rule of Civil Procedure 11 (b) (2) as well as the Eastern District of Texas Local Rules, including but not limited to Local Rule AT-3 (b), stating that a lawyer owes a duty to exercise. On November 7, 2024, the court entered an order directing Monk to show cause why the court should not impose sanctions for his failure to comply with Federal Rule of Civil Procedure 11(b)(2) as well as the Eastern District of Texas Local Rules, including but not limited to Local Rule AT-3(b), stating that a lawyer owes a duty to exercise candor. The lawsuit, Gauthier v. Goodyear Tire & Rubber Co., is being heard in the U.S. District Court for the Eastern District of Texas under case number 1:23-CV-00281. Docket for Gauthier v. Goodyear Tire & Rubber Co., 1:23-cv-00281 — Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information.