# Gauthier v. Goodyear: a Texas lawyer is sanctioned $2,000 for filing AI-hallucinated case citations

> In a wrongful-termination suit, plaintiff's counsel used a generative-AI tool to draft a brief and did not verify it. It cited two cases that do not exist and quotations that could not be located. A federal judge sanctioned him $2,000 and ordered a generative-AI CLE course — a court-adjudicated record of what unverified AI legal drafting costs.

- Verification status: verified
- Case type: deployment
- Provider: Generative-AI legal drafting (attorney-identified as "Claude"; a Lexis AI feature)
- Client: U.S. District Court for the Eastern District of Texas (Hon. Marcia A. Crone) — Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, Courts / legal (AI-governance honest-negative) (named)
- Sector: legal-services / US / cross
- Verified on: 2026-07-24
- Canonical URL: https://theinternetninja.com/stories/gauthier-v-goodyear-attorney-ai-hallucinated-citations-2000-sanction-generative-ai-cle-2024/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| Monetary sanction ordered against counsel | $0 | $2,000 penalty ordered into the registry of the court |
| Generative-AI CLE requirement | None | Ordered to attend a generative-A.I. CLE course (min. one-hour Texas MCLE credit), proof due Feb. 3, 2025 |
| Fabricated authority found in the brief | 0 flagged | 2 cited cases did not exist; multiple quotations could not be located in the cited authority |
| Sanction payment status | Ordered Nov. 25, 2024 | Paid Nov. 26, 2024 (clerk receipt #100022063); recorded satisfied Dec. 5, 2024 |

## Verification method

Court-adjudicated primary: signed U.S. District Court order (Document 48, E.D. Tex., filed Nov. 25, 2024), live-fetched from CourtListener RECAP and byte-tied to a Wayback capture and the Internet Archive RECAP mirror. Two independent secondaries, separately reported, corroborate the $2,000 sanction and the AI-class requirement: Legal Dive (Robert Freedman, Nov. 27, 2024) and Bloomberg Law (Sam Skolnik, Nov. 26, 2024). The court docket records that the penalty was paid and satisfied.

## Full case file

## The problem
Goodyear Tire & Rubber Co. moved for summary judgment in a wrongful-termination lawsuit
(*Gauthier v. Goodyear Tire & Rubber Co.*, No. 1:23-CV-281, E.D. Tex.). On October 2, 2024,
plaintiff's counsel Brandon Monk filed a response opposing that motion. As Goodyear pointed out
in its reply, Monk's response "cites two cases that do not exist" and "includes multiple quotations
that cannot be located within the cited authority." Monk's sur-reply did not address the problem,
and the court entered a show-cause order.

## What was built
Monk explained at the November 21, 2024 show-cause hearing that "he used a generative artificial
intelligence ('A.I.') tool to produce the Response and failed to verify the content." He identified
the tool as "Claude," a generative A.I. tool that can be used for drafting, and said he had used it
in other cases. He also recounted that he "attempted to check the content of the Response by using a
feature available through Lexis AI," but "the Lexis AI feature failed to flag the issues with the
Response." The two fabricated cases were named in the order: *Roca v. King's Creek Plantation, LLC*
and *Beets v. Texas Instruments, Inc.* — neither exists.

## The outcome
Judge Marcia A. Crone found that Monk "failed to make a reasonable inquiry required by Rule 11 and
long-standing precedent into the validity of the arguments he presented," and imposed sanctions "to
deter future improper submissions": Monk was "ordered to pay a $2,000 penalty into the registry of
the court" and "to attend a continuing legal education course, for a minimum of one-hour Texas MCLE
credit, on the topic of generative A.I. in the legal field," with proof of attendance due by
February 3, 2025. He was also ordered to provide a copy of the order to his client. Separately, the
order records that "[a]ccording to counsel for Goodyear, the cost of drafting its reply brief was
$7,521.26" — an attributed representation by opposing counsel, not the sanction figure.

## What happened afterwards
The docket records that the money was paid. On November 26, 2024 the clerk "[i]ssued receipt
#100022063 to Brandon Monk for $2,000.00 in compliance with 48 Order," and on December 5, 2024 the
court entered an "ORDER re sanction imposed on attorney Brandon Monk. Monk has satisfied the monetary
sanction. The Clerk of Court is directed that the $2,000 monetary sanction is a penalty and need not
be held in the court's registry." Two notices of compliance with the sanctions order were filed, on
November 26 and December 19, 2024; the docket text does not say which obligation each documents, so
we do not assert here that proof of the generative-A.I. CLE was filed.

No appeal was taken from the sanctions order. The only appeal in the case is the plaintiff's —
"NOTICE OF APPEAL as to 53 Order & 54 Judgment by James Gauthier," filed January 15, 2025 and
docketed at the Fifth Circuit as No. 25-40021 — which challenges the summary judgment against
Gauthier, not the sanction against his lawyer. A "USCA Mandate" was entered on the district docket on
January 2, 2026; its disposition is behind PACER and we do not state it.

## Path to green
The sanction is stated by an independent federal court in a signed, publicly filed order that is
byte-identical across CourtListener RECAP, a Wayback capture (2024-12-02) and the Internet Archive
RECAP mirror, and it is corroborated by two independent newsrooms — so the figures need no
client-confirmation call to be true. Of the compliance posture that would earn a green badge, the
public docket now answers two of the three questions: the $2,000 was paid and recorded as satisfied,
and the sanctions order was not appealed. One item remains for a human with PACER access: whether the
proof of the ordered generative-A.I. CLE attendance was filed by February 3, 2025 (docket entry 55,
PACER-gated; entry 49 is a scanned image with no text layer).