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Mattox v. Product Innovation Research
, No. 6:24-cv-235-JAR (Oct. 22, 2025)
Case details
Country
United States
Jurisdiction
Federal
Decided
Oct. 22, 2025
filings
ranged
from
summary-judgment
briefing,
to
motions
in
limine,
and
even
a
sanctions
motion.
The
pattern
was
not
inadvertent,
and
it
was
not
harmless.
The
Court
values
trust
among
advocates,
but
trust
must
be
earned
through
verification.
In
this
case,
filings
were
trusted,
but
never
verified,
and
the
results
s
aeak
for
themselves.
After
reviewing
the
record,
conducting
two
show-cause
hearings,
and
considering
the
affidavits,
testimony,
and
argument
of
counsel,
the
Court
finds
that
the
use
of
generative
artificial
intelligence
in
the
preparation
of
these
pleadings
violated
both
Rule
11(b)
of
the
Federal
Rules
of
Civil
Procedure
and
this
Court’s
Al
Guidelines
on
Generative
Al
Disclosure
and
Certification
1
.
1
https://www.oked.uscourts.gov/content/jason-robertson-magistrate-judge
The
integrity
of
judicial
proceedings
depends
on
the
authenticity
of
what
is
filed.
This
case
demonstrates
the
cost
of
neglecting
that
obligation.
II.
BACKGROUND
A.
Procedural
This
case
was
removed
from
state
court
on
July
10,
2024.
Over
the
following
year,
multiple
attorneys
entered
appearances
on
behalf
of
the
plaintiffs:
Gary
R.
Buckles
as
local
counsel
on
July
22,
2024
(Dkt.
12);
T.
Ryan
Scott
on
July
29,
2024
(Dkt.
13);
Sach
D.
Oliver,
admitted
pro
hac
vice
on
August
12,
2024
(Dkt.
17)
and
entering
his
appearance
the
next
day
(Dkt.
18);
and
Harrison
A.
Howie
on
September
16,
2024
(Dkt.
25).
Robert
Lambert,
the
state-court
attorney
who
filed
the
original
petition,
2
6:24-cv-00235-JAR
Document
148
Filed
in
ED/OK
on
10/22/25
Page
2
of
23
never
filed
an
entry
of
appearance
in
federal
court
and
was
permitted
to
withdraw
on
September
8,
2025
(Dkts.
137-138).
On
August
20,
2024,
all
parties
consented
to
the
jurisdiction
of
the
United
States
Magistrate
Judge
assigned
to
this
case.
Fed.
R.
Civ.
P.
73(b)(1).
The
United
States
Magistrate
Judge
exercises
complete
jurisdiction
over
this
case
through
and
including
trial
and
the
entry
of
a
final
judgment
in
accordance
with
28
U.S.C.
§
636(c)(1)
and
Fed.
R.
Civ.
P.
73(a).
(Dkt.
20).
B.
Substantive
On
June
20,
2025,
plaintiffs'
counsel
(Harrison
A.
Howie,
T.
Ryan
Scott,
Sach
D.
Oliver,
and
Robert
Lambert)
filed
a
Sealed
Response
to
Defendants'
Motion
for
Summary
Judgment
("Sealed
Response")
containing
six
(6)
fabricated
case
citations,
three
(3)
erroneous
citations,
three
(3)
quotations
of
nonexistent
law,
and
five
(5)
misstatements
of
law.
[Dkt.
61].
On
June
30,
2025,
plaintiffs'
counsel
filed
a
Motion
for
Partial
Summary
Judgment
containing
one
(1)
fabricated
case
citation
and
two
(2)
misstatements
of
law.
[Dkt.
72].
On
July
2,
2025,
plaintiffs'
counsel
filed
a
Motion
to
Strike
and
Motion
for
Sanctions
containing
two
(2)
fabricated
case
citations.
[Dkt.
g
a
total
78].
Plaintiffs'
counsel
subsequently
filed
six
(6)
Motions
in
Limine
containin
of
four
(4)
fabricated
case
citations,
two
(2)
quotations
of
nonexistent
law,
and
one
(1)
misstatement
of
law.
[Dkts.
89,91,92,93,94,95].
On
July
25,2025,
plaintiffs'
counsel
filed
a
Response
to
Defendants'
Motion
in
Limine
containing
one
(1)
quotation
of
nonexistent
law.
[Dkt.
101].
And
on
July
27,
2025,
plaintiffs'
counsel
filed
a
Reply
in
bricated
Support
of
its
Motion
to
Strike
and
Motion
for
Sanctions
containing
one
(1)
fa
case
citation.
[Dkt.
102].
3
6:24-cv-00235-JAR
Document
148
Filed
in
ED/OK
on
10/22/25
Page
3
of
23
Counsel
for
defendants
filed
a
reply
in
support
of
summary
judgment
on
July
29,
2025,
and
noted
they
were
unable
to
locate
multiple
cases
cited
in
plaintiffs'
Sealed
Response.
[Dkt.
104
at
8].
On
August
4,
2025,
plaintiffs'
counsel
filed
a
Motion
to
Amend
the
Sealed
Response
and
six
Motions
in
Limine
for
the
sole
purpose
of
correcting
"clerical
and
formatting
errors."
[Dkt.
107].
The
Court
thereafter
engaged
in
a
sua
sponte
review
of
each
pleading
submitted
on
behalf
of
plaintiffs
during
the
course
of
this
litigation
and
identified,
inter
alia,
the
following
issues:
•
'Williams
v.
Borden,
Inc.,
637
P.2d
731
(Okla.
1981)
does
not
exist.
See
[Dkt.
61
at
14].
The
Court
found
no
cases
under
that
citation.
There
is
a
Tenth
Circuit
decision
under
that
case
name,
Williams
v.
Borden,
Inc.,
637
F.2d
731
(10th
Cir.
1980),
but
it
does
not
contain
the
law
quoted
by
plaintiffs'
counsel.
•
Case
u.
Fiberboard
Corp.,
1996
OK
86,
943
P.2d
955
does
not
exist.
See
[Dkt.
61
at
14].
The
case
found
at
the
first
half
of
that
citation
is
Brashier
v.
Farmers
Ins.
Co.,
Inc.
1996
OK
86,
925
P.2d
20,
an
action
involving
bad
faith
refusal
to
pay
uninsured
motorist
benefits.
The
case
found
at
the
latter
half
of
that
citation
is
State
v.
Adams,
284
Mont.
25,
943
P.2d
955
(1997),
a
Montana
civil
rights
case.
There
is
an
Oklahoma
Supreme
Court
decision
with
a
similar
case
name,
Case
u.
Fibreboard
Corp.,
1987
OK
79,
743
P.2d
1062,
but
it
does
not
"affirm[]
negligence
claims
for
failure
to
implement
adequate
safety
practices."
[Id.].
product
•
St.
Louis-San
Francisco
Ry.
Co.
v.
Duke,
1959
OK
250,363
P.2d
764
does
not
exist.
See
[Dkt.
61
at
17].
The
case
found
at
the
first
half
of
that
citation
is
Mistletoe
Exp.
Serv.,
Inc.
v.
Culp,
1959
OK
250,
353
P.2d
9,
a
personal
injury
case.
The
Court
found
no
cases
under
the
latter
half
of
that
citation.
•
Brown
v.
Crown
Equip.
Co.,
181
F.
App'x
760
(10th
Cir.
2006)
does
not
exist.
See
[Dkt.
61
at
17,
20].
The
case
found
at
that
citation
is
Burl
v.
Principi,
181
F.
App'x
760
(11th
Cir.
2006),
an
out-of-circuit
employment
discrimination
action.
•
Austin
v.
Ohio
Cas.
Ins.
Co.,
1984
OK
41,
678
P.2d
721
does
not
exist.
See
[Dkt.
61
at
20].
The
case
found
at
the
first
half
of
that
citation
is
Thomas
v.
Bank
of
Okla.,
N.A.,
1984
OK
41,
684
P.2d
553,
a
dispute
over
title
to
property
in
a
revocable
inter
vivos
trust.
The
Court
found
no
cases
under
the
latter
half
of
that
citation.
4
6:24-cv-00235-JAR
Document
148
Filed
in
ED/OK
on
10/22/25
Page
4
of
23
[Dkt.
61
•
Lash
v.
Hollis,
1978
OK
117,
571
P.2d
917
does
not
exist.
See
at
24].
The
case
found
at
the
first
half
of
that
citation
is
Concannon
v.
Hampton,
1978
OK
117,
584
P.2d
218,
an
action
brought
to
register
in
Oklahoma
a
Missouri
judgment
plaintiff
obtained
against
defendant.
The
case
found
at
the
latter
half
to
that
citation
is
Reynolds
v.
Port
of
Portland,
31
Or.
App.
817,
571
P.2d
917,
an
Oregon
personal
injury
action.
•
Creech
v.
Melton,
594
P.2d
408
(Okla.
1979)
does
not
exist.
See
at
2;
Dkt.
92
at
2].
The
Court
found
no
cases
under
that
citation.
[Dkt.
72
•
Two
Old
Hippies
LLC
v.
Catch
the
Bus
LLC,
784
F.
App'x
618
(10th
Cir.
2019)
does
not
exist.
See
[Dkt.
78
at
5].
The
Court
found
no
cases
under
that
citation.
There
is
a
District
of
New
Mexico
decision
under
that
case
name,
Two
Old
Hippies,
LLC
v.
Catch
the
Bus,
LLC,
274
F.R.D.
685
(D.N.M.),
but
it
does
not
affirm
default
judgment
"where
discovery
abuse
irreversibly
prejudiced
the
opposing
party."
[ZdJ.
•
F.D.I.C.
v.
Daily,
973
F.Supp.2d
1116
(D.
Colo.
2013)
does
not
exist.
See
[Dkt.
78
at
5;
Dkt.
102
at
3].
The
Court
found
no
cases
under
that
citation.
There
is
a
Tenth
Circuit
decision
under
that
case
name,
F.D.I.C.
v.
Daily,
973
F.2d
1525
(10th
Cir.
1992),
upholding
the
lower
court's
entry
of
default
judgment
in
favor
of
FDIC
for
failure
to
comply
with
discovery
demands
and
court
orders.
D.
Okla.
•
White
v.
Deer
&
Co.,
No.
13-CV-437-D,
2016
WL
11750888
(W.
Apr.
13,
2016)
does
not
exist.
See
[Dkt.
91
at
2].
The
Westlaw
citat.on
is
an
Answer
Brief
filed
in
a
Florida
Appeals
court.
Morris
v.
Travelers
Indem.
Co.,
518
F.Supp.2d
1245
(W.D.
Okla.
2021)
citation.
does
not
exist.
See
[Dkt.
94
at
3].
The
Court
found
no
cases
under
that
There
is
a
Tenth
Circuit
decision
under
that
case
name,
Morris
v.
Travelers
Indem.
Co.
of
Am.,
518
F.3d
755
(10th
Cir.
2008),
but
it
does
not
contain
the
law
quoted
by
plaintiffs'
counsel.
18
(W.D.
no
cases
•
Kieffer
v.
Weston
Land,
Inc.,
No.
18-CV-794-R,
2021
WL
10996
Okla.
Mar.
22,2021)
does
not
exist.
See
[Dkt.
94
at
3].
The
Court
found
under
that
citation.
There
is
a
Tenth
Circuit
decision
under
that
case
name,
Kieffer
v.
Weston
Land,
Inc.,
90
F.3d
1496
(10th
Cir.
1996),
but
it
does
not
"exclud[e]
lay
opinion
testimony
about
the
cause
of
health
problems."
[ZcL].
•
Tansey
v.
Dacomed
Corp.,
1994
OK
70,
890
P.2d
881
is
an
erroneous
citation.
See
[Dkt.
61
at
24].
The
correct
citation
is
Tansey
v.
Dacomed
Corp.,
1994
OK
146,
890
P.2d
881.
•
Wagoner
v.
Bennett,
1993
OK
100,
814
P.2d
476
is
an
erroneous
citation.
See
[Dkt.
61
at
24-25].
The
correct
citation
is
Wagoner
v.
Bennett,
1991
OK
70,
814
P.2d
476.
5
6:24-cv-00235-JAR
Document
148
Filed
in
ED/OK
on
10/22/25
Page
5
of
23
•
Thompson
v.
Presbyterian
Hosp.
Inc.
,
1982
OK
87,652
P.2d
260
does
not
contain
the
law
quoted
by
plaintiffs'
counsel.
See
[Dkt.
61
at
22].
•
Howard
v.
Zimmer,
Inc.,
299
P.3d
463
(Okla.
2013)
does
not
contain
the
law
quoted
by
plaintiffs'
counsel.
See
[Dkt.
61
at
24].
•
Wyeth
v.
Levine,
555
U.S.
555
(2009)
does
not
contain
the
law
quoted
by
plaintiffs'
counsel.
See
[Dkt.
89
at
2].
•
Dodson
v.
Bd.
ofCty.
Comm'rs,
878
F.Supp.2d
1227
(D.
Kan.
2012)
does
not
hold
what
plaintiffs'
attorneys
purport.
See
[Dkt.
93
at
2].
After
the
Court’s
independent
review
revealed
the
scope
of
the
inaccuracies,
on
August
28,
2025,
the
Court
entered
the
following
minute
order:
«•
Upon
further
review
of
the
documents
filed
by
Plaintiff
in
this
case,
the
hearing
to
receive
argument
on
the
various
pending
motions
in
this
case
set
for
September
3,
2025
at
3:00
p.m.
is
hereby
STRICKEN.
In
lieu
of
that
hearing,
Plaintiffs
counsel
will
be
required
to
appear
before
this
Court
on
SEPTEMBER
11,
20^5
AT
1:30
P.M.
in
Courtroom
3,
Room
432,
U.S.
Courthouse,
5th
|&
Okmulgee,
Muskogee,
OK,
before
Magistrate
Judge
Jason
A.
Robertson,
and
show
cause
as
to
why
sanctions
should
not
be
assessed
for
the
filing
of
multiple
documents
with
this
Court
which
contain
false
or
misleading
information
and
citations.
ALL
COUNSEL
OF
RECORD
REPRESENTING
PLAINTIFF
WILL
BE
REQUIRED
TO
APPEAR
AT
THIS
HEARING.”
(Dkt.
136).
The
show-cause
hearing
was
held
on
September
11,
2025,
at
which
the
Court
received
testimony
and
argument
from
counsel.
At
that
hearing,
Messrs.
Howie
and
Scott
appeared;
Messrs.
Buckles
and
Oliver
did
not.
Following
their
nonappearance,
the
Court
issued
a
Minute
Order
on
September
11,
2025
(Dkt.
142)
directing
Buckles
and
Oliver
to
appear
and
show
cause
why
further
sanctions
should
not
issue
for
failing
to
attend
the
prior
hearing.
That
second
hearing
was
held
on
October
14,2025,
at
which
counsel
appeared
and
were
afforded
a
full
opportunity
to
be
heard.
6
6:24-cv-00235-JAR
Document
148
Filed
in
ED/OK
on
10/22/25
Page
6
of
23
The
matter
was
then
taken
under
advisement
and
is
now
resolved
by
this
written
order.
III.
ANALYSIS
For
the
reasons
set
forth
below,
the
Court
finds
that
plaintiffs'
counsel
violated
their
obligation
under
Rule
11(b),
and
sanctions
are
warranted.
A.
Violations
of
Rule
11(b)
Rule
11(b)
is
the
federal
lawyer’s
first
oath
in
action.
A
standing
promise
that
every
pleading,
motion,
and
argument
submitted
to
a
court
of
the
United
States
rests
on
truth,
law,
and
reason.
It
demands
that
an
attorney’s
signature
certify
not
creativity,
but
credibility:
that
the
filing
was
formed
after
reasonable
inquiry,
grounded
in
fact,
and
supported
by
existing
law
or
a
non-frivolous
argument
for
its
extension.
The
rule
is
not
aspirational;
it
is
the
minimal
standard
of
honesty
that
keeps
the
adversarial
process
tethered
to
reality.
(b)
Representations
to
the
Court.
By
presenting
to
the
court
a
pleading,
written
motion,
or
other
paper—whether
by
signing,
filing,
submitting,
or
later
advocating
it—an
attorney
or
unrepresented
party
certifies
that
to
the
best
of
the
person's
knowledge,
information,
and
belief,
formed
after
an
inquiry
reasonable
under
the
circumstances:
(1)
it
is
not
being
presented
for
any
improper
purpose,
such
as
to
harass,
cause
unnecessary
delay,
or
needlessly
increase
the
cost
of
litigation;
(2)
the
claims,
defenses,
and
other
legal
contentions
are
warranted
by
existing
law
or
by
a
nonfrivolous
argument
for
extending,
modifying,
or
reversing
existing
law
or
for
establishing
new
law;
(3)
the
factual
contentions
have
evidentiary
support
or,
if
specifically
so
identified,
will
likely
have
evidentiary
support
7
6:24-cv-00235-JAR
Document
148
Filed
in
ED/OK
on
10/22/25
Page
7
of
23
I
I
I
after
a
reasonable
opportunity
for
further
investigation
discovery;
and
(4)
the
denials
of
factual
contentions
are
warranted
on
the
evidence
or,
if
specifically
so
identified,
are
reasonably
based
on
belief
or
a
lack
of
information.
This
obligation
is
absolute.
It
cannot
be
outsourced
to
technology
or
delegated
to
co-counsel.
The
attorney’s
signature
is
the
personal
warranty
of
truth
that
anchors
the
judicial
process.
Every
one
of
the
eleven
(11)
pleadings
at
issue
was
signed
by
Harrison
A.
Howie.
By
doing
so,
he
certified
that
each
filing
had
been
reviewed
and
verified
by
human
judgment.
The
record
proves
otherwise.
The
Court’s
independent
review
revealed
twenty-eight
(28)
false
or
misleading
citations:
fourteen
(14)
fabricated
cases
that
do
not
exist
and
fourteen
(14)
erroneous
or
misquoted
authorities.
At
the
September
11
show-cause
hearing,
Mr.
Howie
admitted
that
he
had
used
ChatGPT
“to
make
his
writing
more
persuasive,”
that
the
program
“changed
his
citations,”
and
that
he
did
not
verify
them
before
filing.
None
of
the
eleven
(11)
pleadings
contained
the
disclosure
or
certification
required
by
this
Court’s
Al
Guidelines
on
Generative
Al
Disclosure
and
Certification.
When
defense
counsel
notified
plaintiffs’
attorneys
on
July
29,
2025
(iDkt.
104
at
8)
that
several
cited
cases
could
not
be
located,
Mr.
Howie
did
not
withdraw
or
correct
his
filings.
Instead,
he
filed
a
Motion
to
Amend
on
August
4
(Dkt.
107)
that
described
the
false
authorities
as
“clerical
and
formatting
errors.”
That
explanation
was
inaccurate.
The
problem
was
not
form,
it
was
falsity.
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The
Court
therefore
finds
that
Mr.
Howie
violated
Rule
11(b)(2)
and
(b)(3)
by
presenting
legal
contentions
not
warranted
by
existing
law
and
factual
representations
lacking
evidentiary
support.
His
conduct
also
contravened
the
duty
of
candor
owed
to
the
Court
under
Model
Rule
3.3.
Responsibility
under
Rule
11
extends
to
all
attorneys
of
record.
T.
Ryan
Scott,
who
remained
active
in
hearings
and
discovery;
Sach
D.
Oliver,
the
supervising
partner
admitted
pro
hac
vice;
and
Gary
R.
Buckles,
local
counsel
of
record,
a.l
shared
an
obligation
to
ensure
that
filings
presented
in
their
names
were
accura
te.
None
exercised
that
oversight.
Each
failed
in
their
role
of
verification,
and
the
cumulative
neglect
frustrated
the
administration
of
justice.
B.
Analytical
Framework
for
AI-Generated
Filings
Federal
courts
increasingly
confront
filings
prepared
with
the
assistance
of
generative
artificial
intelligence.
While
such
tools
can
enhance
efficiency,
they
also
create
a
new
professional
hazard,
synthetic
authority
presented
as
precedent.
No
uniform
standard
yet
governs
this
issue.
This
Court
therefore
articulates
the
following
framework,
grounded
in
Rule
11,28
U.S.C.
§
1927,
and
the
Court’s
inherent
authority,
to
guide
this
Court
in
future
cases
in
which
Al-generated
hallucinations
appear
in
filings.
When
a
pleading
containing
fabricated
citations
or
nonexistent
law
has
been
identified
and
a
hearing
held,
this
Court
shall
evaluate
three
core
factors:
1.
Verification
and
Inquiry
—
Whether
counsel
conducted
a
reasonable,
human-
based
verification
of
every
cited
authority
before
filing.
A
reasonable
inquiry
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requires
more
than
reliance
on
an
automated
tool;
it
demands
independent
confirmation
through
recognized
primary
legal
sources.
The
signature
of
an
attorney
certifies
human
diligence,
not
mechanical
output.
2.
Candor
and
Correction
—
Whether
counsel
promptly
disclosed
the
u
se
of
Al
and
corrected
the
record
once
inaccuracies
were
discovered.
Candor
after
filing
weighs
heavily
in
mitigation;
concealment
or
minimization
aggravates
the
violation.
The
duty
of
candor
extends
beyond
the
moment
of
signature,
it
continues
for
as
long
as
the
filing
remains
before
the
Court.
3.
Accountability
and
Supervision
—
Whether
supervising
or
associated
attorneys
exercised
oversight
consistent
with
Model
Rules
5.1
and
5.3
and
whether
firm-level
safeguards
existed
to
prevent
recurrence.
The
inquiry
extends
beyond
the
drafter
to
the
institutional
culture
that
permitted
unverified
authority
to
reach
the
docket.
A
firm’s
silence
or
absence
of
policy
does
not
immunize
it;
it
implicates
it.
These
factors
balance
culpability
against
mitigation
and
aim
to
deter
repetition
rather
than
destroy
reputation.
They
also
provide
a
path
for
future
litigants
in
this
Court
when
confronting
Al-related
misconduct,
recognizing
that
the
issue
implicates
the
ethical
foundations
of
advocacy
itself.
C.
Application
of
the
Framework
1.
Verification
and
Inquiry
Mr.
Howie’s
admission
that
he
relied
on
ChatGPT
without
verifying
its
citations
demonstrates
the
total
absence
of
human
inquiry.
Fourteen
(14)
fabricated
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cases
and
fourteen
(14)
misquoted
authorities
appeared
across
eleven
(11)
pl
eadings:
All
signed
by
him
and
filed
without
certification.
The
volume
and
repetition
of
these
errors
show
not
inadvertence
but
systemic
neglect.
By
contrast,
Mr.
Scott
and
Mr.
Oliver
did
not
draft
the
pleadings
but
remained
counsel
of
record
and
continued
to
rely
on
them
in
hearings,
depositions,
and
conferences.
Their
failure
to
examine
or
question
the
filings
before
advocacy
reflects
a
secondary
lapse
of
verification
Mr.
Buckles,
as
local
counsel,
admitted
he
never
reviewed
the
pleadings
and
entered
his
appearance
merely
“as
a
favor.”
His
abdication
eliminated
the
local
check
Rule
11
is
designed
to
provide.
Collectively,
the
absence
of
verification
at
every
level
satisfies
the
first
factor
and
represents
the
core
breach.
2.
Candor
and
Correction
When
defense
counsel
raised
the
issue
on
July
29,
2025,
plaintiffs’
attorneys
did
not
investigate
or
correct
the
record.
Their
Motion
to
Amend
of
August
4
(Dkt.
107)
characterized
the
false
citations
as
“clerical.”
That
assertion
misled
the
Court
and
opposing
counsel.
At
the
show-cause
hearing,
Mr.
Howie
admitted
the
use
of
ChatGPT
only
after
direct
questioning.
No
earlier
disclosure
was
made.
Mr.
Scott
and
Mr.
Oliver
likewise
made
no
corrective
filing
despite
knowing
the
Court
was
investigating.
The
duty
of
candor
was
breached
both
before
and
after
the
Court’s
intervention.
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3.
Accountability
and
Supervision
The
Oliver
Law
Firm,
which
referred
the
case
to
Mr.
Howie,
maintained
active
involvement
in
discovery
and
strategy
but
had
no
policy
governing
Al
use
for
cases
referred
to
outside
counsel
and
apparently
conducted
no
review
of
pleadings.
Its
inattention
enabled
the
misconduct.
Local
counsel
Gary
R.
Buckles
provided
no
supervision
and
failed
even
to
attend
the
first
show-cause
hearing,
requiring
a
second
order
compelling
his
appearance.
Such
passivity
reflects
a
misunderstanding
of
the
role
of
local
counsel,
which
is
fiduciary,
not
ceremonial.
The
third
factor
therefore
weighs
heavily
in
favor
of
sanctions.
D.
Findings
under
the
Framework
All
three
factors
(verification,
candor,
and
accountability)
are
met.
Each
demonstrates
a
breach
of
the
attorney’s
fundamental
duty
of
reasonable
inquiry
and
honesty
to
the
tribunal.
The
Court
does
not
find
that
Mr.
Howie
acted
with
intent
to
deceive
Rule
11
does
not
require
intent;
it
requires
responsibility.
An
attorney
who
signs
eleven
(11)
pleadings
containing
fabricated
authority,
after
using
an
undisclosed
Al
program
and
making
no
effort
to
verify
a
single
citation,
acts
with
reckless
disregard
for
the
truth.
Recklessness
in
this
context
is
not
a
lapse
of
diligence;
it
is
the
conscious
de
cisión
to
proceed
in
the
absence
of
knowledge.
Repetition
across
eleven
(11)
p
leadings
magnifies
that
recklessness
and
transforms
neglect
into
misconduct.
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The
same
reasoning
applies,
though
to
a
lesser
extent,
to
the
supervisory
and
associated
counsel.
Their
continued
participation
without
inquiry
or
correction
reflected
indifference
to
accuracy
once
the
falsity
was
known.
Each
owed
the
Court,
and
the
profession,
more
than
silence.
Accordingly,
the
Court
concludes
that
plaintiffs’
counsel
collectively
violated
Rule
11(b).
Their
conduct,
though
not
bom
of
deceit,
displayed
a
reckless
disregard
for
the
obligation
to
ensure
that
what
is
filed
in
federal
court
is
true,
verified,
and
worthy
of
the
public
trust.
Sanctions
are
therefore
warranted
both
to
redress
the
specific
harm
and
to
deter
recurrence.
IV.
SANCTIONS
For
guidance,
the
Court
looks
to
other
cases
that
have
sanctioned
attorneys
for
similar
conduct.
In
nearly
all
cases,
courts
have
imposed
monetary
sanctions
ranging
from
$1,500
to
$15,000.
See
e.g.
f
Wadsworth
v.
Walmart
Inc..
348
F.R.D.
48S
,
499
(D.
Wyo.
2025)
($3,000
fine
for
the
drafter
of
the
brief
with
fake
cases
and
$1,000
for
other
attorneys
who
signed,
but
did
not
draft,
the
brief);
United
States
v.
Haves.
No.
Gauthier
v.
Goodyear
Tire
&
Rubber
Co..
No.
23-CV-281,
2024
WL
4882651
at
*3
(E.D.
Tex.
Nov.
25,
2024)
($2,000
fine);
Mid
Cent.
Operating
Eng'rs
Health
&
Welfare
Fund
v.
Hoosiervac
LLC.
No.
24-CV-326,
2025
WL
574234
at
*2-3
(S.D.
Ind
2025
(recommending
$15,000
fine);
Mata
v.
Avianca,
Inc.,
678
F.Supp.3d
Feb.
21,
443,
459
(S.D.N.Y.
2023)
($5,000
fine
for
citing
fake
cases
and
then
submitting
AI-generated
fake
excerpts
from
the
fake
cases).
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In
some
cases,
courts
have
referred
attorneys
to
the
appropriate
disciplinary
body
for
disciplinary
proceedings.
See
e.g.,
Park
v.
Kim,
117
F.4th
610,
614
(2d
Cir.
2024)
(referring
attorney
to
Second
Circuit's
Grievance
Panel);
Hayes,
763
F.Supp.3d
at
1072-73
(directing
Clerk
of
Court
to
serve
copy
of
sanctions
order
on
bar);
Bevins,
2025
WL
1085695
at
*7
(directing
Clerk
of
Court
to
serve
copy
of
sanctions
order
on
two
bars);
Dehghani,
2025
WL
988009
at
*6
(ordering
attorney
to
self-report
sanctions
order
to
two
bars);
Hoosiervac
LLC,
2025
WL
574234
at
*2-3
(referring
attorney
to
the
Southern
District
of
Indiana's
Grievance
Panel).
In
addition
to
monetary
sanctions,
courts
have
imposed
more
targeted
sanctions
given
the
circumstances
by
revoking
the
pro
hac
vice
admi
ssion
of
attorneys,
Wadsworth,
348
F.R.D.
at
497-98,
directing
the
Clerk
of
Court
tc
serve
a
copy
of
the
sanctions
order
on
all
district
and
magistrate
judges
in
the
district,
Haves,
763
F.Supp.3d
at
1072-73,
ordering
attorney's
fees
be
paid
to
opposing
counsel
for
having
to
respond
to
pleadings
containing
fake
cases,
Garner
v.
Kadince,
Inc.,
2025
UT
App
80,
H
16,
571
P.3d
812,
816,
requiring
the
attorney
to
mail
letters
to
each
2024
WL
4882651
at
*3,
or
ordering
the
attorney
to
attend
CLE
trainings
regarding
the
use
of
judge
falsely
identified
as
the
author
of
nonexistent
opinions,
Gauthier,
Al,
Dehghani,
2025
WL
988009
at
*6;
Gauthier.
2024
WL
4882651
at
*3;
Bunce
v.
Visual
Tech.
Innovations,
Inc.,
No.
23-CV-1740,
2025
WL
662398
(E.D.
Pa.
Feb.
27,
2025).
The
message
from
these
cases
is
unmistakable:
when
attorneys
abandon
verification,
they
abandon
their
oath.
Artificial
intelligence
may
explain
an
error,
but
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it
can
never
excuse
one.
The
sanction
must
therefore
speak
not
only
to
the
lawyers
before
this
Court,
but
to
every
lawyer
tempted
to
trade
diligence
for
speed.
The
rule
is
simple
and
enduring:
truth
is
not
negotiable,
and
the
signature
on
a
pleading
still
means
something.
A.
Application
of
Sanctions
to
Individual
Counsel
When
this
Court
first
considered
appropriate
monetary
sanctions,
it
1
ooked
to
recent
cases
addressing
the
submission
of
Al-generated
or
fabricated
authorities.
In
Wadsworth
v.
Walmart
Inc.
,
348
F.R.D.
489
(D.
Wyo.
2025),
fines
reached
$3,000
per
drafter
and
$1,000
per
signer.
In
Mata
v.
Avianca,
Inc.,
678
F.
Supp.
3d
443
(S.D.N.Y.
2023),
the
sanction
was
$5,000
for
counsel
who
submitted
six
(6)
fictitious
citations.
Those
cases
involved
one
or
two
pleadings.
Here,
the
misconduct
spanned
eleven
(11)
pleadings
and
twenty-eight
(28)
false
or
misleading
citations:
fourteen
(14)
fabricated,
and
fourteen
(14)
erroneous
or
misquoted.
Based
on
that
scope,
the
Court
initially
contemplated
fines
in
the
range
between
$10,000
and
$15,000
for
the
drafter
and
proportionate
amounts
for
the
others.
However,
the
Court
also
heard
testimony
and
observed
demeanor
at
two
hearings.
Every
attorney
appeared
(eventually),
admitted
the
wrongdoing,
accepted
responsibility,
and
fell
upon
the
mercy
of
the
Court.
None
denied,
deflected,
or
excused.
Their
contrition
was
genuine
and
complete.
Rule
Il’s
purpose
is
deterrence,
not
destruction.
The
public
reprimands
issued
in
this
Order,
together
with
joint
restitution
of
attorney’s
fees
and
the
permanent
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record
of
these
findings,
will
deter
far
more
effectively
than
excessive
fines.
The
Court
therefore
exercises
restraint
and
imposes
reduced
but
meaningful
sanctions
,
$2,000,
calibrated
to
each
attorney’s
degree
of
responsibility.
These
amounts
($3,000
edibility
and
$1,000)
stand
as
tangible
reminders
that
candor
is
the
currency
of
cr
before
this
Court.
Harrison
A.
Howie
—
Signing
and
Drafting
Attorney
Mr.
Howie
drafted
and
signed
every
pleading
at
issue.
By
his
own
admission,
he
used
ChatGPT
to
“make
his
writing
more
persuasive,”
allowed
it
to
alter
citations,
and
filed
the
resulting
briefs
without
verification.
His
actions
were
reckless
but
not
deceitful.
At
the
September
11
hearing,
he
accepted
full
responsibility
and
fell
upon
the
mercy
of
the
Court.
He
has
demonstrated
sincere
remorse.
The
Court
credits
his
candor.
While
his
conduct
represented
a
profound
failure
of
professional
duty,
it
also
presents
a
rare
opportunity
for
public
correction
rather
than
professional
ruin.
referral.
Monetary
Sanction:
$3,000
Public
Reprimand:
Issued
by
this
Order
Bar
Referral:
None.
The
Court
finds
no
intentional
deception
warranting
Continued
Representation:
Mr.
Howie
may
remain
as
counsel
of
record,
subject
to
the
continuing
duty
to
verify
all
future
filings
personally
and
to
certify
compliance
with
this
Order.
T.
Ryan
Scott
—
Referring
Counsel
and
Active
Participant
Mr.
Scott
did
not
draft
or
sign
the
defective
pleadings
but
remained
counsel
of
record
and
relied
upon
them
throughout
the
case.
His
failure
to
question
their
accuracy
reflected
neglect
of
oversight,
not
malice.
At
the
hearing
he
admitted
that
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omission,
accepted
fault,
and
has
since
instituted
firm
policies
requiring
verification
of
all
Al-assisted
filings.
The
Court
initially
considered
a
sanction
of
$4,000
to
$5,000
based
on
his
supervisory
role,
but
his
candid
acknowledgment
of
responsibility
and
corrective
action
warrant
mitigation.
Monetary
Sanction:
$2,000
Public
Reprimand:
Issued
by
this
Order
Bar
Referral:
None.
This
sanction
reflects
his
secondary
role
while
reaffirming
that
supervision
is
a
duty,
not
a
courtesy.
Sach
D.
Oliver
—
Managing
Partner
(pro
hac
vice)
As
managing
partner,
Mr.
Oliver
authorized
the
referral
to
Mr.
Hcwle
and
remained
counsel
of
record.
He
had
no
policy
governing
Al
use
by
associated
counsel
and
conducted
no
independent
review
of
filings
submitted
in
his
firm’s
name.
That
absence
of
supervision
allowed
unverified
authorities
to
reach
the
docket.
At
the
October
14
hearing,
Mr.
Oliver
accepted
full
accountability
and
pledged
immediate
reforms
within
his
firm.
The
Court
originally
considered
a
sanction
of
$2,500
to
$3,000
but,
in
light
of
his
honest
testimony
and
remedial
steps,
concludes
that
a
reduced
penalty
will
adequately
deter
recurrence.
Monetary
Sanction:
$1,000
Public
Reprimand:
Issued
by
this
Order
Bar
Referral:
None.
The
sanction
recognizes
limited
direct
involvement
yet
underscores
that
firm
leaders
remain
guardians
of
their
name
and
their
firm’s
reputation
on
every
pleading.
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Gary
R.
Buckles
—
Local
Counsel
of
Record
Mr.
Buckles
entered
his
appearance
as
local
counsel
on
July
22,
2024
(IDkt.
12).
He
never
met
the
client,
never
reviewed
the
pleadings,
and
did
not
participate
in
supervising
out-of-district
counsel.
He
failed
to
appear
at
the
September
11
learing,
requiring
a
second
show-cause
order
compelling
his
attendance
on
October
14.
By
his
own
admission,
his
role
was
purely
“as
a
favor”
to
the
original
state-court
attorney.
That
description
underscores
the
systemic
risk
of
honorary
sponsorships.
Mr.
Buckles’
neglect
as
local
counsel
did
not
create
the
hallucinated
authorities,
but
it
enabled
them.
His
name
on
the
docket
gave
those
pleadings
a
presumption
of
legitimacy
that
they
did
not
deserve.
When
a
lawyer
lends
his
signature,
or
his
silence,
to
filings
without
inquiry,
he
converts
inattention
into
representation
and
transforms
friendship
into
liability.
His
conduct
eroded
the
safeguard
that
local
representation
is
meant
to
provide.
through
irdless
of
Public
Reprimand:
Mr.
Buckles
shall
receive
a
formal
public
reprimand
this
Order.
The
reprimand
serves
to
clarify
that
an
attorney
of
record,
rega
degree
of
involvement,
is
accountable
for
the
accuracy
of
filings
submitted
under
his
or
her
name.
Eastern
Restriction
on
Sponsorship:
For
a
period
of
twelve
(12)
months,
Mr.
Buckles
may
not
serve
as
sponsoring
or
local
counsel
for
any
pro
hac
vice
attorney
in
the
District
of
Oklahoma.
After
that
period,
reinstatement
of
sponsorship
privileges
will
be
automatic.
These
sanctions,
though
measured,
are
neither
symbolic
nor
lenient.
They
reflect
the
Court’s
confidence
that
deterrence
arises
from
conscience
as
much
as
from
cost.
The
combination
of
public
reprimands,
individual
fines,
and
full
restitution
of
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attorney’s
fees
restores
the
balance
Rule
11
demands:
truth
verified,
accountability
imposed,
and
integrity
reaffirmed.
All
counsel
are
admonished
that
the
trust
restored
today
must
be
maintained
tomorrow.
The
record
of
this
Order
will
stand
as
both
warning
and
witness
that
verification
is
not
optional,
and
that
mercy
in
this
Court
is
always
tethered
to
responsibility.
B.
Remedial
Correction
of
the
Record
The
purpose
of
sanctions
under
Rule
11
is
not
only
to
deter
future
misconduct
but
also
to
restore
the
integrity
of
the
record
already
before
the
Court.
Pleadings
that
rely
upon
fabricated
or
erroneous
authorities
cannot
remain
on
the
docket.
They
misstate
the
law,
distort
the
issues,
and
leave
the
Court
to
build
upon
a
foundation
that
no
longer
exists.
Accordingly,
all
filings
identified
in
this
Order
as
containing
fabricated
or
inaccurate
citations
are
hereby
STRICKEN
from
the
record.
This
includes
the
following
docket
entries:
61,
72,
78,
89,
91,
92,
93,
94,
95,101
and
102.
Within
sixty
(60)
days
of
the
date
of
this
Order,
Plaintiffs
shall
file
verified
amended
pleadings
that
show
as
follows:
1.
drafted
and
reviewed
by
human
counsel
without
the
use
of
generative
artificial
intelligence
tools
to
produce
or
alter
text
or
citations,
except
as
expressly
permitted
by
this
Court’s
Al
Guidelines
on
Artificial
Intelligence
Disclosure
and
Certification;
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2.
contain
only
accurate
and
verifiable
authorities;
and,
3.
are
accompanied
by
a
signed
Certification
of
Verification
confirming
that
counsel
personally
reviewed
each
cited
case,
statute,
or
exhibit
for
accuracy.
The
Certification
shall
state:
“I
certify
that
I
personally
reviewed
each
citation
and
authority
referenced
in
this
pleading
and
that,
to
the
best
of
my
knowledge
and
belief,
all
citations
are
genuine
and
accurately
reflect
the
law
as
of
the
date
of
filing.
This
filing
complies
with
the
requiremen
ts
of
the
Court’s
Al
Guidelines
on
Artificial
Intelligence
Disclosure
and
Certification.”
esult
in
Failure
to
file
verified
pleadings
within
the
sixty-day
period
will
i
dismissal
of
those
claims
without
further
notice.
This
directive
is
restorative.
The
record
must
reflect
truth
before
the
Court
!
may
apply
law.
The
Federal
Rules
presuppose
a
foundation
of
accuracy,
arid
where
!
that
foundation
has
been
compromised,
the
only
remedy
is
reconstruction.
The
Court
therefore
wipes
the
slate
clean,
in
the
service
of
veracity.
Having
restored
the
integrity
of
the
record,
the
Court
now
turns
to
the
question
of
cost,
specifically,
the
burden
unjustly
borne
by
opposing
counsel
in
responding
to
pleadings
that
rio
longer
exist.
C.
Award
of
Attorney’s
Fees
and
Costs
Under
Rule
11(c)(4),
a
sanction
"may
include
...
an
order
directing
pairment
to
the
movant
of
part
or
all
of
the
reasonable
attorney’s
fees
and
other
expenses
directly
resulting
from
the
violation.”
The
Court
finds
that
the
defendants’
counsel
incurred
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substantial
expense
responding
to
the
fabricated
filings
and
addressing
the
procedural
disruption
that
followed.
The
Affidavit
of
Theresa
N.
Hill,
lead
counsel
for
defendants
Cosway
Company,
Inc.
and
Product
Innovations
Research,
LLC,
establishes
that
her
firm,
Rhodes,
Hieronymus,
Jones,
Tucker
&
Gable,
PLLC,
expended
$23,423.50
in
attorney
fees
and
$72.40
in
costs,
for
a
total
of
$23,495.90,
in
connection
with
these
pleadings
and
the
resulting
hearings.
The
Court
finds
these
fees
and
expenses
reasonable
and
directly
caused
by
the
violations
identified
in
this
Order.
Accordingly,
pursuant
to
Rule
11(c)(4),
the
Court
orders
joint
and
several
reimbursement
of
these
amounts
by
the
Howie
Law
Firm
and
the
Oliver
Law
Firm,
in
equal
shares.
Each
firm
shall
remit
$11,747.95
to
defense
counsel
within
thirty
(30)
days
of
this
Order.
This
obligation
is
separate
from
the
individual
monetary
sanctions
imposed
above
and
shall
not
be
borne
by
local
counsel
Gary
R.
Buckles.
The
Court
directs
defense
counsel
to
file
a
short
notice
of
compliance
once
payment
is
received.
The
purpose
of
these
sanctions
is
not
punitive
but
restorative:
to
restore
the
meaning
of
local
appearance
and
to
reinforce
the
Court’s
expectation
that
every
lawyer
of
record,
regardless
of
title,
stands
as
both
advocate
and
guarantor
of
integrity.
The
Court
expects
compliance
not
because
it
demands
perfection,
but
because
the
justice
system
cannot
function
without
verification.
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V.
CONCLUSION
The
Court
has
imposed
sanctions
to
restore,
not
to
ruin.
The
aim
of
this
ruling
is
not
punishment
for
its
own
sake,
but
the
reaffirmation
of
professional
honor.
All
counsel
have
appeared,
accepted
responsibility,
and
sought
mercy.
The
Court
has
answered
with
proportion,
acknowledging
their
contrition
while
ensuring
accountability
endures.
The
combination
of
public
reprimand,
restitution,
and
monetary
penalty
satisfies
the
Rule
11
standard
of
deterrence
and
reaffirms
that
the
practice
of
law
is
an
act
of
trust.
The
lesson
is
neither
new
nor
novel.
The
practice
of
law
has
never
been
about
convenience;
it
has
always
demanded
courage.
The
quiet,
disciplined
courage
to
stand
for
what
is
right
when
compromise
would
be
easier.
Marcus
Aurelius
wrote
I
“If
it
is
not
right,
do
not
do
it;
if
it
is
not
true,
do
not
say
it.”
Meditations
bk.
12,
§
17
(Gregory
Hays
trans.,
Modern
Library
ed.
2002).
That
simple
maxim
captures
the
heart
of
advocacy:
the
moral
courage
to
write,
to
argue,
and
to
sign
only
what
truth
can
defend.
It
takes
courage
to
put
a
word,
a
sentence,
a
phrase
to
paper
in
defense
of
another.
It
takes
courage
to
sign
one’s
name
beneath
arguments
that
carry
the
weight
of
justice.
Machines
can
assemble
words,
but
they
cannot
believe
in
them.
They
can
process
information,
but
they
cannot
possess
conviction.
The
Court
does
not
fear
progress.
It
fears
abdication.
When
lawyers
trade
reflection
for
automation,
they
surrender
the
very
quality
that
makes
their
words
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