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

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, in the U.S. District Court for the Eastern District of Texas. On October 2, 2024, plaintiff’s counsel Brandon Monk filed a response opposing that motion. As Goodyear observed 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,” and Monk’s sur-reply “failed to address the issues,” so the court entered a show-cause order (source).

What was built

At the November 21, 2024 show-cause hearing, Monk “explained that he used a generative artificial intelligence (‘A.I.’) tool to produce the Response and failed to verify the content” (source). The order records that Monk “explained that he used ‘Claude,’ which is a generative A.I. tool that can be used for drafting,” and “stated that he has used Claude in other cases and is in the process of verifying other submissions he had made to the court” (source). Monk further 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” (source). The two nonexistent cases named in the order are Roca v. King’s Creek Plantation, LLC and Beets v. Texas Instruments, Inc. (source).

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” (source).

The monetary sanction: $2,000. Monk was “ordered to pay a $2,000 penalty into the registry of the court” (source).

The training order: a generative-AI CLE, minimum one-hour Texas MCLE credit. Monk was ordered “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 and submit proof to the court of his attendance by February 3, 2025,” and to provide a copy of the order to his client and certify on the docket within 21 days (source).

The fabricated authority: 2 nonexistent cases plus uncitable quotations. The order names Roca v. King’s Creek Plantation, LLC and Beets v. Texas Instruments, Inc. as the two cases that do not exist, alongside quotations that “cannot be located within the cited authority” (source).

The order also records that “[a]ccording to counsel for Goodyear, the cost of drafting its reply brief was $7,521.26” (source). That figure is an attributed representation by opposing counsel stated at the hearing, not the sanction amount, and is presented here as such rather than as an audited cost.

How this was verified

This case carries a green badge as a court-adjudicated primary record. The sanction is stated by an independent federal court in a signed, publicly filed order (Document 48, filed November 25, 2024), whose full text was re-fetched and re-checked figure by figure on 2026-08-08 from the archived copy hosted by Courthouse News, and every quoted figure above appears verbatim in that order. Two independent newsrooms reported the same $2,000 sanction and generative-AI course requirement, so the figures need no client-confirmation call to be true. Bloomberg Law’s report sits behind a paywall and is treated as a headline-only corroboration; the byte-checkable independent secondary is Legal Dive.

The honest limit: the order itself is fully verifiable, but the post-order docket events (the payment receipt, any December 2024 order recording the penalty as satisfied, and whether the proof of generative-AI CLE attendance was filed by February 3, 2025) are PACER and CourtListener-authentication-gated and were not re-verifiable in this pass, so none of those specifics is asserted here.

Related case files

The same failure, an attorney filing AI-fabricated citations and drawing a Rule 11 sanction, runs through Wadsworth v. Walmart, where Morgan and Morgan self-reported and still drew a $5,000 sanction, a useful contrast with Monk, who did not correct the brief until the court ordered him to. Gardner v. Combs is another single-attorney Rule 11 fine in the same range for a fabricated citation. Kruse v. Karlen shows the scale the same conduct can reach, 22 of 24 citations fake and a $10,000 sanction on appeal.

Sources

Cited in this case file. Tier 1 = the court’s own signed order; Tier 2 = independent press naming the parties; Tier 3 = paywalled or aggregated report. Each figure was checked against the live source on 2026-08-08.

1. U.S. District Court, E.D. Texas, “Memorandum and Order,” Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, Document 48, signed by Judge Marcia A. Crone, filed 2024-11-25 (Tier 1, primary court order; archived copy hosted by Courthouse News). https://www.courthousenews.com/wp-content/uploads/2024/11/attorney-sanctioned-for-using-ai-hallucinations.pdf
2. Legal Dive, Robert Freedman, “Another lawyer in hot water for citing fake GenAI cases,” 2024-11-27 (Tier 2, independent legal press; confirms the $2,000 fine and the AI class). https://www.legaldive.com/news/another-lawyer-in-hot-water-citing-fake-genai-cases-brandon-monk-marcia-crone-texas/734159/
3. Bloomberg Law, Sam Skolnik, “Lawyer Sanctioned Over AI-Hallucinated Case Cites, Quotations,” 2024-11-26 (Tier 3, independent but paywalled; headline-only corroboration). https://news.bloomberglaw.com/litigation/lawyer-sanctioned-over-ai-hallucinated-case-cites-quotations