Davila v. Roblen (Feb. 6, 2026)

Case details
Full caption
Raul Gonzales Davila v. Roblen
Country
United States
Jurisdiction
Connecticut (CT)
Court
Connecticut Supreme Court
Decided
Feb. 6, 2026
Majority
Stefan R. Underhill (J.) (unanimous Court)
RAUL GONZALES DAVILA, Plaintiff, v. ROBLEN, LLC f/d/b/a..., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 323134Only the Westlaw citation is currently available.United States District Court, D. Connecticut.RAUL GONZALES DAVILA, Plaintiff,v.ROBLEN, LLC f/d/b/a VICOLO PIZZARESTAURANT and VIKTOR BERISHA, Defendants.No. 3:23-cv-00512 (SRU)|Filed 02/06/2026Editor's Note: This decision contains discussion of citationreferences that are incorrect or do not actually exist. Theseinvalid citations appeared in the original court opinion andhave been preserved as written since they are part of theofficial record. Any links to these invalid citations have beenremoved.SANCTIONS ORDERStefan R. Underhill United States District JudgeI. Introduction*1 In the instant action, David Stich, counsel for plaintiffRaul Gonzales Davila, filed a brief containing AI-generatedquotes from legal authorities that did not contain those quotes.See, e.g., Doc. No. 71 at 18-19 (citing fake AI-generatedquotes).1Before the brief's hallucinated AI-generated quotes came tolight, Stephanie Stich, David Stich's co-counsel and daughter,contacted my chambers and asked about filing a “correctedversion” of the brief. See Doc. No. 84 at 1-2. Stephanie Stichnever acknowledged that they sought to file a “correctedversion” because the filed version contained hallucinated AI-generated quotes.In deciding whether David Stich and Stephanie Stich deservesanctions, I balance two competing facts. On one hand, theirconduct did not meet the professional standards required of allattorneys. On the other hand, both David Stich and StephanieStich recognize the seriousness of their mistakes and havecommitted to taking affirmative steps to avoid any future AI-related legal errors.I must decide whether David Stich and Stephanie Stich'sconduct deserves sanctions.II. Factual BackgroundDavid Stich and Stephanie Stich represent the plaintiff, animmigrant with limited English language proficiency, in hissuit against his former employer for violations of state andfederal minimum wage and overtime laws. See Complaint,Doc. No. 1, 1-2, 6, 12.David Stich has previously come before this Court to addressconcerns about his use of AI in legal filings. In a parallelcase to the instant action, Judge Janet C. Hall ordered DavidStich to show cause for why he should not be sanctionedfor submitting a memorandum of law containing hallucinatedAI-generated citations to non-existent cases. See Cojom v.Roblen, LLC, Dkt. No. 3:23-CV-01669 (JCH), Doc. No. 49.Judge Hall determined that the most appropriate sanction forDavid Stich was $500. See Cojom v. Roblen, LLC., 2025 LX524310, at *10 (D. Conn. Nov. 17, 2025).III. Legal Standarda. David StichDavid Stich filed a brief containing fake AI-generated quotesand did not review those citations before filing the brief.This Court has the “inherent power to ‘manage [its] ownaffairs so as to achieve the orderly and expeditious dispositionof cases.’ ” United States v. Seltzer, 227 F.3d 36, 41 (2d Cir.2000) (quoting Chambers v. NASCO, Inc., 501 U.S. 32, 50,115 L. Ed. 2d 27, 111 S. Ct. 2123 (1991)). Courts can invokethat inherent authority to address attorney conduct and imposesanctions. See id.; see also Palmer v. Simon's Agency, Inc.,833 F. App'x 838, 839 (2d Cir. 2020).A finding of bad faith is not a prerequisite to impose sanctions.Id. See also Seltzer, 227 F.3d at 41. Absent a finding ofbad faith, attorneys can only be sanctioned for conduct thatinvolves “a lawyer's negligent or reckless failure to performhis or her responsibility as an officer of the court.” Seltzer, 227F.3d at 41. But to sanction attorney conduct “that is integrallyrelated to the attorney's role as an advocate for his or herclient,” id. at 40, courts must first find that the attorney actedin bad faith. Id.
RAUL GONZALES DAVILA, Plaintiff, v. ROBLEN, LLC f/d/b/a..., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2b. Stephanie Stich*2 In a telephone call to my chambers, Stephanie Stich failedto disclose to this Court that she and David Stich sought tofile a different version of their brief because it contained fakeAI-generated quotes.The Connecticut Rules of Professional Conduct governStephanie Stich's behavior.2 Under Rule 3.3 of theConnecticut Rules of Professional Conduct, Stephanie Stichhas a duty of candor to the tribunal. Conn. Rules of Pro.Conduct 3.3.IV. Discussiona. David StichOn behalf of the plaintiff, David Stich filed a memorandumof law in opposition to the defendants’ motion for summaryjudgment. That brief contained multiple AI-generated quotesfrom legal authorities that did not contain those quotes.For instance, the plaintiff maintained that he was individuallycovered under the Fair Labor Standards Act (“FLSA”). Insupport of that argument, the brief cited Pineda v. Frisolino,Inc., 2017 WL 3835882 (S.D.N.Y. Aug. 29, 2017). Pineda isa real decision dealing with the FLSA. The brief then quotedPineda as stating that “any regular contact with goods thathave moved in interstate commerce is sufficient.” Doc. No.71 at 18-19. That reveals the problem: the quoted languagedoes not appear in the Pineda decision. The brief used thePineda quote to help establish individual coverage, leavingthe plaintiff with arguments based on fake law.By causing that avoidable legal mishap, David Stich“negligent[ly]...[failed] to perform [his] responsibility as anofficer of the court.” Seltzer, 227 F.3d at 41. He usedan AI tool, the tool then generated fake quotes, and hebased arguments on those fake quotes. Most importantly,David Stich never “conduct[ed] a reasonable inquiry into theviability of” the brief. See Cojom, 2025 LX 524310 at *5(quoting AJ Energy LLC v. Woori Bank, 829 F. App'x 533,535 (2d Cir. 2020) (summary order). David Stich's conductwas not “part of [his] legitimate efforts at zealous advocacyfor the client.” Seltzer, 227 F.3d at 40. Accordingly, to imposesanctions, I need not find that David Stich acted in bad faith.Id.David Stich's conduct negatively impacted his client, theopposing parties and their counsel, and this Court. DavidStich deprived his client of arguments “based on legitimatejudicial precedent.” See Cojom, 2025 LX 524310 at *7.The opposing parties and their counsel had to contend with“arguments based on phony law.” Id. Finally, this Courtexpended time and resources to investigate and address DavidStich's conduct.I must also consider David Stich's response to his errors.He admitted that he did not check the quotes and citationsproduced by the AI tool and took responsibility for thoseerrors. See Doc. No. 83 at 2. He then committed to neverusing any AI research tools for legal practice and to takingcontinuing legal education programs on the responsible useof AI in legal practice. Id.Balancing David Stich's accountability for his errors againsthis irresponsible use of AI in a legal filing, I order that DavidStich must (a) complete at least three hours of continuing legaleducation on the responsible use of AI in legal practice, and(b) share his new knowledge regarding AI and legal practicewith the Connecticut legal community in written form (e.g., ablog post, op-ed, or letter to the editor).b. Stephanie Stich*3 As stated previously, Stephanie Stich contacted mychambers and asked about filing a “corrected version” of thebrief. See Doc. No. 84 at 2. However, Stephanie Stich was notcandid with my chambers. She never acknowledged that theysought to file a “corrected version” because the filed versioncontained hallucinated AI-generated quotes.After I ordered Stephanie Stich to show cause why she shouldnot be sanctioned for her lack of candor, she responded ina contrite and productive manner. She apologized for herconduct and indicated that she was currently enrolled incontinuing legal education programs on the responsible useof AI in legal practice. See Doc. No. 84 at 2.Although Stephanie Stich may not have been entirely candidwith this Court, her conduct does not merit sanctions. Shedid not lie or deceive this Court. She did not make a “a falsestatement of fact or law.” Conn. Rules of Pro. Conduct 3.3. Itherefore decline to impose sanctions on Stephanie Stich.V. ConclusionFor the reasons discussed above, I order that David Stich (a)complete at least three hours of continuing legal educationon the responsible use of AI in legal practice, and (b) share
RAUL GONZALES DAVILA, Plaintiff, v. ROBLEN, LLC f/d/b/a..., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.3his new knowledge regarding AI and legal practice with theConnecticut legal community in written form. I decline toimpose sanctions on Stephanie Stich.So ordered.Dated at Bridgeport, Connecticut, this 6th day of February2026.All CitationsSlip Copy, 2026 WL 323134Footnotes1Those fake AI-generated quotes are known as “hallucinations,” which are “false facts generated by GenAIsystems.” Zach Warren, GenAI hallucinations are still pervasive in legal filings, but better lawyering isthe cure, Thomas Reuters (Aug. 18, 2025), https://www.thomsonreuters.com/en-us/posts/technology/genai-hallucinations/.2Rule 83.2(a)(1) of the District of Connecticut Local Rules subjects attorneys practicing in the District ofConnecticut to the Connecticut Rules of Professional Conduct. See Phillips v. Berlex Labs., Inc., 2006 U.S.Dist. LEXIS 27389, at *14 n.4 (D. Conn. May 5, 2006).End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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