A federal judge fined a lawyer $5,000 for filing AI-fabricated case citations against T.D. Jakes

The problem

Bishop Thomas Dexter (T.D.) Jakes sued Duane Youngblood for defamation in the U.S. District Court for the Western District of Pennsylvania, No. 2:24-cv-01608-WSS (source). Youngblood’s counsel, Tyrone A. Blackburn, filed briefs supporting a motion to dismiss that the court found to “contain wholly fabricated quotations from caselaw” including “fabricated quotations from the Court’s own prior opinion” (source). Even after the court flagged the problem, a review of the reply brief showed that it “too includes fabricated quotes and misrepresents case law” (source).

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 order names no specific product and describes the “system” only as generative AI that Blackburn used to draft the briefs, which the court presumed when it wrote that it “presumes that Youngblood’s briefs were constructed by generative artificial intelligence used by Blackburn, rather than an effort by Blackburn to personally construct false and misleading briefs” (source). The court added that it “does not matter, as attorneys have ethical obligations under Rule 11” to review every document they file (source).

The outcome

On June 25, 2025, Judge William S. Stickman IV struck the offending motion and reply and called the conduct “a clear ethical violation of the highest order” (source). After further briefing, the court on October 6, 2025 imposed the monetary sanction and revoked Blackburn’s admission to appear in the case (source).

The sanction that gets quoted: $5,000 under Rule 11, payable to plaintiff’s counsel in “monthly payments of not less than five hundred dollars ($500) to plaintiff’s counsel until the $5,000 is paid in full,” with the first payment due on or before November 15, 2025 (source).

The fee request that was refused: $76,197.63. Jakes had asked for more than $76,000 in attorneys’ fees, which the court denied as unreasonable, on the view that Rule 11 exists to deter rather than to compensate (source). The underlying defamation dispute, which is unrelated to the AI issue, was jointly dismissed in October 2025, and the dismissal did not disturb the sanction (source).

How this was verified

This is a court-origin record, so the badge is granted against the public record, not against any party’s confirmation. The two operative orders, the June 25, 2025 order striking the briefs (ECF No. 53) and the October 6, 2025 order imposing the sanction (ECF No. 71), are on the CourtListener RECAP docket (69412014) as image-only scans (source). Because the scans carry no extractable text, the verbatim court language quoted here is bound to Reason/Volokh’s reproduction of the June 25 order, and the $5,000, $500/month and $76,197.63 figures are independently reported by Christian Post (source). The honest limit is the image-only nature of the primary scans: every quotation and figure was re-checked live on 2026-08-16 against these independent secondaries rather than lifted from a text-bearing court file.

Related case files

The same attorney, Tyrone Blackburn, drew a larger Rule 11 penalty for an AI-hallucinated case in Gardner v. Combs, where a New Jersey federal court fined him $6,000 on the same $500-a-month schedule. Blackburn’s fabricated-quotation pattern recurs again in Dixon v. Cartagena, where an SDNY court struck his filings and referred him to a grievance committee. For a same-amount comparison from a different firm, see Wadsworth v. Walmart, where Morgan & Morgan attorneys were fined $5,000 in total for AI-hallucinated citations and one lost a pro hac vice admission, as Blackburn did here.

Sources

Tiers: Tier 1 primary (the court’s own record); Tier 2 strong secondary (independent press naming the parties); Tier 3 weak (marketing, PR, or aggregators). All URLs checked live on 2026-08-16.

1. CourtListener, “Jakes v. Youngblood, No. 2:24-cv-01608, docket 69412014,” accessed 2026-08-16 (Tier 1, the primary federal docket; the June 25 and Oct 6 orders are image-only scans). https://www.courtlistener.com/docket/69412014/jakes-v-youngblood/
2. Reason / The Volokh Conspiracy, “Whoever or Whatever Drafted the Briefs Signed and Filed by Blackburn,” 2025-06-26 (Tier 2, independent legal press reproducing the June 25, 2025 order verbatim). https://reason.com/volokh/2025/06/26/whoever-or-whatever-drafted-the-briefs-signed-and-filed-by-blackburn/
3. The Christian Post, “Judge denies most of $76K legal fees sought by TD Jakes,” October 2025 (Tier 2, independent press reporting the $5,000 sanction, $500/month terms and the $76,197.63 fee denial from the Oct 6 order). https://www.christianpost.com/news/judge-denies-most-of-76k-legal-fees-sought-by-td-jakes.html
4. The Roys Report, “Jakes, Youngblood End Legal Battle Over Sexual Assault Claims With Joint Dismissal,” October 2025 (Tier 2, independent press reporting the October 2025 joint dismissal of the underlying defamation case). https://roysreport.com/jakes-youngblood-end-legal-battle-over-sexual-assault-claims-with-joint-dismissal/