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Case Intel:

• Indiana federal judge recommends $7,500 sanctions against employment attorney for submitting discovery brief with fabricated case citations
• Attorney blamed paralegal's rushed work but judge found "most logical explanation" was generative AI usage
• Sanctions include financial penalty, chief judge referral, and mandatory client notification within 14 days

An Indiana federal judge has recommended sanctioning an employment attorney $7,500 after discovering fabricated legal citations in a discovery brief, highlighting the persistent challenges lawyers face when incorporating artificial intelligence into their practice without proper safeguards.

U.S. Magistrate Judge Mark J. Dinsmore issued the sanctions recommendation Tuesday against attorney Tae Sture of Sture Legal Services LLC, who represents a woman suing Marion County Superior Court Juvenile Detention Center for employment discrimination. The judge found Sture's response to a motion to compel contained what he called a "rather bizarre amalgamation of several cases" and citations to nonexistent legal authority.

The sanctions stem from litigation filed by Indiana resident Yvonne L. Davis against the Marion County Superior Court Juvenile Detention Center and its chief operations officer. Davis alleges Title VII sex discrimination and First Amendment retaliation after being terminated in 2022 for alleged "untrustworthiness" and subsequently denied rehire.

When defendants filed a July 28 motion to compel discovery, Sture had just three days to respond. His July 31 brief included problematic citations that caught Judge Dinsmore's attention during review.

During a show cause hearing, Sture attributed the faulty citations to his paralegal's rushed drafting of the document under deadline pressure, denying any use of generative AI tools. However, Judge Dinsmore remained skeptical.

"The most logical explanation for the citation to non-existent authority is, of course, the use of generative AI to conduct legal research and/or draft the brief," Judge Dinsmore wrote in his recommendation.

Crucially, the judge emphasized that AI usage itself wasn't the problem. "There is nothing fundamentally improper in the use of AI tools to draft a brief," he noted. "Rather, it is counsel's abdication of his responsibility to ensure that the information he provided to the court was accurate that is the basis for the sanctions recommended."

The decision echoes a growing number of federal and state rulings over the last three years where lawyers have stumbled by submitting filings with fabricated authorities. Judges have made clear they are not anti-AI—what they oppose is sloppy lawyering that fails to validate what is presented as binding law.