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.
Judge Dinsmore’s recommended sanctions include:
- $7,500 personal financial penalty against Sture
- Referral of Sture’s conduct to the court’s chief judge
- Mandatory provision of sanction order copy to client Davis
- Required certification of client notification
Sture has 14 days to file objections to the recommendation.
The judge found Sture violated Indiana Rules of Professional Conduct and Federal Rule 11 by failing to conduct reasonable inquiry into the law before filing his brief, regardless of whether AI generated the problematic citations.
The defendants in the case are represented by Matthew Rayman, Caitlin Wilkinson, Jessica Reagan Gastineau, and Kiely C. Keesler of the City of Indianapolis Office of Corporation Counsel.
