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). Youngblood’s counsel, Tyrone A. Blackburn (T. A. Blackburn Law, PLLC), filed briefs supporting a motion to dismiss that, in the court’s words, contained “wholly fabricated quotations from caselaw — including fabricated quotations from the Court’s own prior opinion.” Even after the court flagged the problem, Blackburn’s reply brief contained further fabricated quotations. The court “presume[d] that Youngblood’s briefs were constructed by generative artificial intelligence used by Blackburn.”

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) that Blackburn used to draft legal briefs and then filed without verifying, producing citations and quotations to cases that do not say what he claimed, and in some instances to quotations that do not exist.

The outcome

On June 25, 2025, Judge William S. Stickman IV struck the offending motion and reply, called the conduct “a clear ethical violation of the highest order,” and ordered Blackburn to show cause why he should not be sanctioned under Rule 11(b). After briefing and a July 24, 2025 hearing, the court on October 6, 2025 imposed a $5,000 monetary sanction on Blackburn under Rule 11, payable to plaintiff’s counsel in “monthly payments of not less than five hundred dollars ($500) … until the $5,000 is paid in full,” and revoked his pro hac vice status. The court denied the $76,197.63 in attorneys’ fees Jakes had requested as an unreasonable measure, holding that “the main purpose of Rule 11 is to deter, not to compensate.” (The $76,197.63 is what Jakes asked for and did not get — not the sanction.) The separate defamation dispute is unrelated to the AI issue and was voluntarily dismissed on October 16, 2025, which did not vacate the sanction.

Verification status: PENDING — publish-ready, awaiting HUMAN client-confirmation; not verified. The operative sanction order (ECF No. 71) is a scanned, image-only PDF; at maker handoff it had no confirmed web-archive capture. In checking (2026-07-24) that gap was closed: the order was captured to the Wayback Machine and byte-tied to the local PDF (sha1-b32 V6QHV4S2MZBFDXGTAONOP73HT2O5EY5O = live CDX digest), exactly as the June 25 order (ECF No. 53) already was. The $5,000 figure is bound to two independent newsrooms that quote the order (Christian Post and AllHipHop) plus Reason/Volokh’s verbatim reproduction of the June 25 order, atop the now-archived court order itself.

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 can advance, the checker must close the archive/extraction gap on the Oct 6, 2025 order (ECF No. 71): re-poll the web-archive index for the storage.courtlistener.com copy and byte-tie it (sha1-b32 V6QHV4S2MZBFDXGTAONOP73HT2O5EY5O), and ideally obtain a text-bearing or OCR’d copy so the $5,000 language can be quoted from the order itself rather than via the newsrooms. The checker should also confirm no post-dismissal vacatur, reconsideration, or appeal of the sanction (RECAP docket 69412014).