# A federal judge struck a lawyer's brief over 17 AI-fabricated quotations and folded the conduct into a grievance referral > In the consolidated Fat Joe litigation (Dixon v. Cartagena, S.D.N.Y.), Magistrate Judge Jennifer E. Willis granted Roc Nation's motion to strike attorney Tyrone A. Blackburn's opposition brief on July 10, 2026 because it contained AI-hallucinated citations — Blackburn did not dispute that on seventeen occasions he put language in quotation marks that does not appear in the cited cases — leaving the sanctions motion unopposed and adding the conduct to his SDNY Grievance Committee referral. - Verification status: verified - Case type: deployment - Provider: Generative AI used by counsel to draft a legal brief (the order names no specific product; press reports a LexisNexis tool, which is not in the order) - Client: U.S. District Court for the Southern District of New York — Dixon v. Cartagena / Cartagena v. Dixon, No. 25 Civ. 5144 & 25 Civ. 3552 (Hon. Jennifer E. Willis, U.S. Magistrate Judge), Courts / legal (AI-governance honest-negative) (named) - Sector: legal / US / cross - Verified on: 2026-08-01 - Canonical URL: https://theinternetninja.com/stories/dixon-v-cartagena-sdny-blackburn-ai-fabricated-quotations-struck-grievance-referral-2026/ - Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform ## Outcomes | Metric | Before | After | | --- | --- | --- | | Roc Nation's motion to strike attorney Tyrone A. Blackburn's opposition to a sanctions motion was GRANTED on July 10, 2026; the sanctions motion is now considered unopposed, with a separate sanctions order to follow | | | | Blackburn did not dispute that on seventeen occasions his brief placed language in quotation marks that is not identical to language in the cited cases; the court rejected his 'paraphrase or compression' defense | | | | The court folded the fabricated-quotation conduct into an existing referral of Blackburn to the S.D.N.Y. Grievance Committee, citing 'a pattern of complete disregard for his ethical obligations to make accurate representations to the Court' | | | ## Verification method Court-origin honest-negative. Primary: the July 10, 2026 Order (Dkt. No. 220, Hon. Jennifer E. Willis), retrieved from storage.courtlistener.com (RECAP docket nysd 641455 / 3552) as a text-bearing 7-page PDF and byte-tied to the Wayback Machine (sha1-b32 2ZSGH6C6Q7FZ5I2D3RLBFMHC7GZI2AXY = live CDX digest, capture 20260712094823). Verbatim rulings ('seventeen occasions', 'motion to strike ... is GRANTED', Grievance Committee referral) are additionally carried by two independent archive-bound newsrooms: Reason/Volokh (Eugene Volokh, 2026-07-10, reproduces the order) and AllHipHop (2026-07, independent narration: '17 different occasions ... he didn't dispute it'). ## Full case file ## The problem Joseph Cartagena — the rapper Fat Joe — is in consolidated litigation in the Southern District of New York with his former hype-man Terrance "T.A." Dixon and Dixon's attorney, Tyrone A. Blackburn (*Dixon v. Cartagena*, No. 25 Civ. 5144; *Cartagena v. Dixon*, No. 25 Civ. 3552). On June 1, 2026, Roc Nation LLC moved for sanctions against Dixon, Blackburn, and T.A. Blackburn LLC. Blackburn's July 1, 2026 opposition brief was, in Roc Nation's words, "untimely, exceeds this Court's word limit, and contains what appear to be AI-hallucinated citations." ## What was built Nothing was built here — this is an AI-governance honest-negative, published because a verifiable, independent adjudicator put the failure on the record. The "system" is generative AI (the order names no specific product; press reports Blackburn attributed some citations to a LexisNexis research tool, a detail that does **not** appear in the order) used to draft a legal brief that was filed without verifying that the quoted language actually appears in the cited cases. ## The outcome On **July 10, 2026**, Magistrate Judge Jennifer E. Willis **granted** Roc Nation's motion to strike, so "the motion for sanctions will be considered unopposed" and "a separate Order on the motion for sanctions will follow." The court found that "Blackburn does not dispute that on **seventeen occasions** he included language in quotation marks that is not identical to language in the cited cases" — and rejected his defense that such language was "a paraphrase or compression that faithfully states the court's holding." Rather than concede, Blackburn had counter-accused Roc Nation of forty citation errors of its own; Roc Nation replied that "some of Plaintiff's accusations are based on hallucinations from the very 'assisted citation-verification tool' Plaintiff claims to have used." Finding "a pattern of complete disregard for his ethical obligations to make accurate representations to the Court," Judge Willis noted the referral of Blackburn to the S.D.N.Y. Grievance Committee already made "in its last Order on sanctions," and ordered that "this behavior will be incorporated in his referral to the Grievance Committee." The order recites that this is a repeat pattern: a W.D. Pa. court "ultimately imposed a monetary sanction against Blackburn for **five thousand dollars**" in *Jakes v. Youngblood* (2025), and the District of New Jersey sanctioned him in *Gardner v. Combs* (Dec 2025) for citing AI-hallucinated nonexistent cases. **This order imposes no dollar sanction of its own** — the amount, if any, will come in the separate order that "will follow." **Verification status: PENDING — checker-graduated, awaiting HUMAN client-confirmation. NOT verified from the war-room.** The primary is the court's own text-bearing order, byte-tied to the Wayback Machine, with two independent newsrooms carrying the same rulings verbatim. ## Path to green This is a court-origin record, so no client-confirmation call is owed against the court — a published federal order is self-authenticating. Before it advances, the checker should (1) confirm no vacatur, reconsideration, or appeal of the July 10, 2026 strike order on the RECAP docket, and (2) treat the forthcoming monetary sanctions order as a **separate future record** — no dollar figure may be attached to this story until that order is filed, retrieved, and byte-tied.