Gentry v. Thompson, No. 25-1260 (2026)

Case details
Full caption
Daniel Gentry v. Calvin Thompson et al.
Country
United States
Jurisdiction
Federal
Decided
2026
Majority
Carl J. Barbier (J.) (unanimous Court)
DANIEL GENTRY v. CALVIN THOMPSON ET AL., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 787563Only the Westlaw citation is currently available.United States District Court, E.D. Louisiana.DANIEL GENTRYv.CALVIN THOMPSON ET AL.CIVIL ACTION NO. 25-1260|03/20/2026Attorneys and Law FirmsDaniel Gentry, New Orleans, LA, Pro Se.Jalen R. Harris, Charline K. Gipson, James MichaelRoquemore, The City of New Orleans Law Department, NewOrleans, LA, Corwin St. Raymond, City Attorney's Office,New Orleans, LA, Donesia D. Turner, City of New Orleans,New Orleans, LA, for Calvin Thompson, Latoya W. Cantrell,New Orleans City, New Orleans Police Department, KimeraDufeal Woods, Perrin Gaines, Ernest C. Luster, Leonard E.Bendy, Gary J. Lacabe, Christopher Jennings.Jalen R. Harris, James Michael Roquemore, The City ofNew Orleans Law Department, New Orleans, LA, Corwin St.Raymond, City Attorney's Office, New Orleans, LA, DonesiaD. Turner, City of New Orleans, New Orleans, LA, for J. Diaz.CARL J. BARBIER, UNITED STATES DISTRICT JUDGESECTION: “J”(3)ORDER AND REASONS*1 On March 5, 2026, the Court ordered counsel forDefendants in the above-captioned matter, Jalen R. Harris,James M. Roquemore, Corwin St. Raymond, and Charline K.Gipson, to show cause why they should not be sanctioned forfailure to comply with Federal Rule of Civil Procedure 11.Specifically, the brief that defense counsel signed and filedin support of their Rule 12(b)(6) Motion to Dismiss (Rec.Doc. 16) contained nine nonexistent (i.e., “hallucinated”)case citations. Harris, Roquemore, St. Raymond, and Gipsonappeared before the Court on Thursday, March 19, 2026, at9:30 a.m.FACTS AND PROCEDURAL BACKGROUNDOn June 18, 2025, Plaintiff Daniel Gentry brought claimsagainst the City of New Orleans, then-Mayor LaToyaCantrell, the New Orleans Police Department (“NOPD”), andindividual NOPD officers (hereinafter “the City Defendants”)for violations of his civil and constitutional rights and fortortious conduct. In January of 2026, the City Defendantsfiled a motion, along with a supporting memorandum, todismiss Mr. Gentry's claims pursuant to Rule 12(b)(6) andbased on qualified immunity. (Rec. Doc. 16). When reviewingthe motion, the Court realized that nine of the case citationsDefendants provided in the supporting brief did not exist ascited and were likely “hallucinated” by artificial intelligence(“A.I.”). On March 5, the Court issued an Order to ShowCause why defense counsel should not be sanctioned underFederal Rule of Civil Procedure 11. Between the time theCourt issued the Order to Show Cause and the hearing date,defense counsel also moved for leave to file a substitutepleading to replace the brief that included hallucinatedcitations, in addition to responding to the Rule to Show Causein writing. From the time they received the Order to ShowCause, the City Attorneys have taken full responsibility forthe improper use of A.I. that led to the hallucinated casecitations. On March 19, the attorneys for the City of NewOrleans who had signed the motion, Jalen Harris, JamesRoquemore, Corwin St. Raymond, and Charline Gipson,appeared before the Court for the Show Cause hearing.LEGAL STANDARDRule 11 of the Federal Rules of Civil Procedure requires that“at least one attorney of record” or an unrepresented partymust sign “[e]very pleading, written motion, and other paper”filed with a federal court. Fed. R. Civ. P. 11. Further, Rule 11explains what an attorney represents to the court when s/hesigns a filing and provides for sanctions when a party violatesthe rule. In relevant part, Rule 11(b) reads as follows:(b) Representations to the Court. By presenting to thecourt a pleading, written motion, or other paper—whetherby signing, filing, submitting, or later advocating it—anattorney or unrepresented party certifies that to the best ofthe person's knowledge, information, and belief, formedafter an inquiry reasonable under the circumstances:
DANIEL GENTRY v. CALVIN THOMPSON ET AL., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2* * *(2) the claims, defenses, and other legal contentions arewarranted by existing law or by a nonfrivolous argumentfor extending, modifying, or reversing existing law or forestablishing new law....Fed. R. Civ. P. 11(b).*2 The affirmative duties imposed by Rule 11 apply to allpleadings, written motions, and other papers submitted to acourt. See Fed. R. Civ. P. 11(a); Thomas v. Capital Sec. Servs.,836 F.2d 866, 870 (5th Cir. 1988) (en banc). Thus, when alitigant files a pleading or motion, he certifies that he hasconducted a reasonable inquiry into both the facts and the lawcontained in the filing, and that to the best of his knowledge,information, and belief, the pleading, written motion, or otherpaper has adequate legal and factual support. See Fed. R. Civ.P. 11(b); Childs v. State Farm Mut. Auto. Ins. Co., 29 F.3d1018, 1023–24 (5th Cir. 1994).In determining whether a litigant has violated Rule 11,courts apply an objective (rather than subjective) standardof reasonableness. See id. at 1024 (citing United States v.Alexander, 981 F.2d 250, 252 (5th Cir. 1993)). The conduct ofthe litigant is assessed at the time he submitted the offendingpleading or motion. Id.; see also Thomas, 836 F.2d at 874–75 (citing Fed. R. Civ. P. 11 Advisory Comm. Notes). Rule11 also authorizes the court, on its own initiative, to “imposean appropriate sanction on any attorney, law firm, or partythat violated the rule or is responsible for the violation” when“after notice and a reasonable opportunity to respond, thecourt determines that Rule 11(b) has been violated.” Fed. R.Civ. P. 11(c)(1), (c)(3).DISCUSSIONAt the Show Cause Hearing on March 19, Jalen Harrisacknowledged that he was the attorney who was primarilyresponsible for drafting the offending memorandum. Heexplained that when he started to outline the brief, he wantedto find cases from federal courts in Louisiana to support hislegal propositions. Mr. Harris began by searching for relevantcases on Westlaw but admitted that he eventually resorted toChatGPT. Mr. Harris took full responsibility for his misuseof generative A.I. and conceded that he did not check thecitations that ChatGPT had provided, nor did he attempt toread the nine hallucinated cases that he cited in the brief.Mr. Harris is a young attorney who has been with the CityAttorney's office since 2024. He appeared genuinely contriteand apologized to the Court more than once, in addition toassuring the Court that he would never make this mistakeagain. Using ChatGPT and failing to check the case citations itprovides constitute not only a lapse in professional judgment,but also a violation of Federal Rule of Civil Procedure 11.Furthermore, Rule 11 implicitly requires that attorneys readthe cases they cite in court filings to determine whethertheir arguments are supported by law. Applying an objectivestandard of reasonableness, the Court concludes that Mr.Harris undoubtedly violated this rule. That being said, theCourt was also impressed by the forthright way in which Mr.Harris accepted accountability for his conduct.Next, the Court heard from James Roquemore, who alsoapologized to the Court. Mr. Roquemore explained that as Mr.Harris's immediate supervisor, he reviewed Mr. Harris's briefbefore it was filed and made substantial revisions to othersections of the memorandum. Mr. Roquemore acknowledgedthat he should have inquired further about the hallucinatedcases cited in the memorandum, particularly because of theunusual formatting (the hallucinated cases were presented inbullet points), but he admitted that he failed to do so. Mr.Roquemore is a Deputy City Attorney, and as a supervisingattorney, Mr. Roquemore has the important duty of ensuringthat he and the attorneys who report to him read each citedcase and check every citation before filing a motion or otherpleading with a court. Moreover, Mr. Roquemore has beenpracticing law for roughly thirty years. Due to both hissupervisory role and his extensive experience in the practiceof law, the Court finds that he bears more responsibility forthe violation of Rule 11 than Mr. Harris does.*3 The Court also heard from Mr. St. Raymond, ChiefDeputy City Attorney, and newly appointed City AttorneyCharline Gipson. First, it is important to note that Ms. Gipsonwas not enrolled in this case when the motion at issue wasfiled, and in fact, she was not sworn in to her new roleas City Attorney until January 12, 2026, only three daysbefore Defendants’ motion was filed. The Court ordered herto appear because as City Attorney, her name was in thesignature block on the pleading, and the Court wanted to findout how her office intended to address the now endemic andnationwide problem of attorneys’ improper use of A.I.Both Mr. St. Raymond and City Attorney Gipson outlinedthe actions the City Attorney's Office has taken tocombat the future misuse of A.I. Specifically, the City
DANIEL GENTRY v. CALVIN THOMPSON ET AL., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.3Attorney's Litigation Division called a department-widemeeting immediately after the Court issued the Order toShow Cause in this matter, and Ms. Gipson and her staffare currently in the process of developing a written policyconcerning the use of generative A.I. in the City Attorney'sOffice. Further, Mr. Harris and Mr. Roquemore attended aThomson Reuters seminar about proper and improper usesof A.I. in legal practice. Ms. Gipson also emphasized theimportance of reading every single case that an attorney citesin a brief, and she discussed the importance not only oftask leadership, but also, and more importantly, of peopleleadership.Finally, it also came to the Court's attention on March 19that Defendants had not served any of the filed motions onpro se Plaintiff Daniel Gentry, who also attended the hearing,nor had they filed certificates of service in the record. Basedon the Court's order, Defendants served Mr. Gentry with allpending motions via email and by U.S. mail and filed acertificate of service in the record promptly after the hearing.(Rec. Doc. 23).The Court acknowledges and appreciates the fact that theattorneys for Defendants graciously took accountability forthe offending pleading and that they sincerely apologized tothe Court. Furthermore, the Court recognizes that Mr. Harrisis a relatively new attorney and that his supervisors bearsome responsibility for not noticing the hallucinated citations,particularly considering that they were formatted in bulletpoints. Rule 11 requires that the Court provide due process, ornotice and a hearing, before imposing sanctions for violationsof Rule 11. Here, the Court issued the Order to Show Cause,which constituted notice for the hearing that was held onMarch 19. Therefore, the Court has complied with the due-process requirement and finds that defense counsel in thiscase violated Rule 11.CONCLUSIONAccordingly,IT IS HEREBY ORDERED that under Federal Rule of CivilProcedure Rule 11, Jalen Harris is personally sanctioned forhis conduct in this case in the amount of $250.00.IT IS FURTHER ORDERED that James Roquemore ispersonally sanctioned in the amount of $1,000.00.IT IS FURTHER ORDERED that the sanctions are to bepaid by 5:00 p.m. on Wednesday, April 22, 2026, toClerk of CourtU.S. District Court for the Eastern District of Louisiana 500Poydras Street, Room C151 New Orleans, Louisiana 70130The Court has chosen not to impose a sanction on CorwinSt. Raymond, but this Order should serve as a formaladmonishment concerning the improper use of A.I. by theattorneys in his department.New Orleans, Louisiana, this 20th day of March, 2026.CARL J. BARBIERUNITED STATES DISTRICT JUDGEAll CitationsSlip Copy, 2026 WL 787563End of Document© 2026 Thomson Reuters. No claim to original U.S.Government Works.
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