Federal Judge Sanctions Attorney in TCPA Case Over AI-Related False Citations
Case Snapshot
- Case: McCormick v. Texakoma Financial, Inc.
- Court: U.S. District Court for the Eastern District of Texas
- Decision Date: June 11, 2026
- Issue: Whether an attorney should be sanctioned after submitting a filing containing fictitious legal authorities, fabricated quotations, and inaccurate legal propositions that appeared to result from the use of generative AI.
- Outcome: The court imposed sanctions, struck the plaintiff’s summary judgment response, ordered a $5,000 penalty, required corrective actions and continuing legal education, and mandated additional verification requirements for the attorney’s future court filings.
A federal judge in Texas has imposed sanctions on an attorney in a Telephone Consumer Protection Act (TCPA) case. The court found that a filing contained fictitious legal authorities, fabricated quotations, and inaccurate legal propositions that appeared to stem from the use of generative artificial intelligence (AI).
In McCormick v. Texakoma Financial, Inc., decided on June 11, 2026, the U.S. District Court for the Eastern District of Texas issued a detailed sanctions order. It warned that courts have seen a growing number of cases involving fraudulent legal citations associated with generative AI tools. The decision underscores the judiciary’s increasing scrutiny of attorneys’ professional responsibilities when using AI-assisted legal research.
Court Rejects Attorney’s Explanation
The sanctions order arose after the plaintiff’s response to a motion for summary judgment cited a non-existent case, included fabricated quotations, and misstated legal principles.
According to the court, attorney Amy L.B. Ginsburg, who signed the filing, was ordered to explain how the errors occurred.
After reviewing her explanation, the court found it unpersuasive. The judge concluded that the attorney’s account lacked credibility and stated that the explanation appeared to shift responsibility to others rather than acknowledge the errors.
The court further observed that inaccurate case names, citations, and quotations reflected more than ordinary research mistakes, characterizing the issue as one involving candor and professional responsibility.
Filing Stricken and Monetary Penalty Imposed
As part of its ruling, the court struck the plaintiff’s response opposing the defendant’s motion for summary judgment and ordered a corrected filing within five days.
The court also imposed a $5,000 monetary penalty, holding Ginsburg and her law firm jointly responsible for payment.
In addition, the court authorized the defendant to seek attorney’s fees related to identifying and addressing the fictitious legal authorities, subject to further proceedings.
Extensive Corrective Measures Ordered
Beyond the financial sanction, the court ordered several additional corrective measures.
Among them, Ginsburg must review every filing bearing her signature submitted in any federal or state court between Jan. 1, 2026, and the date of the order. The review must verify the accuracy of every cited legal authority, including case law, statutes, regulations, quotations, and secondary sources.
If any additional inaccuracies are discovered, the attorney must notify the affected courts and parties and take steps to correct the record.
The court also required Ginsburg to file a sworn certification confirming completion of the review within 90 days.
Additional Compliance Requirements
The sanctions order includes several other requirements intended to reinforce future compliance.
The court directed that:
- The order will be served on every district judge and magistrate judge within the Eastern District of Texas.
- The opinion has been directed to be published in the Federal Supplement.
- Ginsburg must provide a copy of the order to her client.
- Ginsburg must complete at least two hours of continuing legal education covering the ethical use of artificial intelligence, candor to the court, or related topics.
- For one year, every filing Ginsburg submits in the court that cites legal authority must include a signed certification confirming that each citation has been personally verified.
AI Continues to Raise Ethical Questions for the Legal Profession
The ruling reflects a broader trend as courts increasingly confront filings containing inaccurate legal citations allegedly generated through AI tools.
Federal courts across the United States have issued sanctions and disciplinary orders in recent years after attorneys submitted briefs containing fabricated cases or inaccurate legal authorities generated by generative AI applications.
The McCormick decision adds to that body of case law by emphasizing that attorneys remain personally responsible for verifying the accuracy of every legal authority submitted to the court, regardless of the technology used during drafting or research.
Broader Implications
The decision serves as another reminder that while AI tools are becoming more common in professional practice, courts continue to expect attorneys to independently verify legal research and maintain their ethical obligations to clients and the judiciary.
As generative AI becomes more widely used across the legal profession, decisions such as McCormick v. Texakoma Financial, Inc. are likely to shape professional standards governing the appropriate use of AI in litigation and reinforce the importance of accuracy, diligence, and candor in court filings.
