A U.S. District Judge in Santa Ana fined law firm Hagens Berman, partner Robert Carey and co-counsel Celeste Boyd a total of $13,000 for improper use of AI-generated material in a lawsuit involving Fenix International Ltd., the parent company of OnlyFans.
Court filings showed four briefs contained legal citations produced by OpenAI’s ChatGPT that were fabricated and did not correspond to legitimate precedents, violating ethical requirements that arguments be grounded in existing law.
The ruling noted Boyd used AI assistance during drafting but failed to verify the citations. Hagens Berman attempted to attribute the errors to outside co-counsel and sought to replace the filings, but the court denied those efforts, stating corrected versions could not erase the initial misconduct.
The judge dismissed the case but allowed the plaintiffs to amend their complaint, giving them an opportunity to refile with properly substantiated documentation.
The decision underscores the risks of unverified AI use in legal work and signals heightened scrutiny from courts. Legal professionals are urged to treat AI tools as aids that require rigorous verification and accountability.
The case is likely to prompt law firms, courts and bar associations to develop stricter standards, training and internal protocols to ensure AI-assisted submissions receive thorough review before filing.
The ruling serves as a reminder that technological innovation in legal practice must be balanced with precision, accountability and adherence to ethical obligations.
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