Gentry et al v. Thompson et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
DANIEL GENTRY 	CIVIL ACTION
VERSUS 	NO. 25-1260
CALVIN THOMPSON ET AL. 	SECTION: “J”(3)
ORDER AND REASONS
On March 5, 2026, the Court ordered counsel for Defendants in the above-
captioned matter, Jalen R. Harris, James M. Roquemore, Corwin St. Raymond, and
Charline K. Gipson, to show cause why they should not be sanctioned for failure to
comply with Federal Rule of Civil Procedure 11. Specifically, the brief that defense
counsel signed and filed in support of their Rule 12(b)(6) Motion to Dismiss (Rec. Doc.
16) 	contained 	nine 	nonexistent 	(i.e., 	“hallucinated”) 	case 	citations. 	Harris,
Roquemore, St. Raymond, and Gipson appeared before the Court on Thursday, March
19, 2026, at 9:30 a.m.
FACTS AND PROCEDURAL BACKGROUND
On June 18, 2025, Plaintiff Daniel Gentry brought claims against the City of
New Orleans, then-Mayor LaToya Cantrell, the New Orleans Police Department
(“NOPD”), and individual NOPD officers (hereinafter “the City Defendants”) for
violations of his civil and constitutional rights and for tortious conduct. In January of
2026, the City Defendants filed a motion, along with a supporting memorandum, to
dismiss Mr. Gentry’s claims pursuant to Rule 12(b)(6) and based on qualified
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immunity. (Rec. Doc. 16). When reviewing the motion, the Court realized that nine of
the case citations Defendants provided in the supporting brief did not exist as cited
and were likely “hallucinated” by artificial intelligence (“A.I.”). On March 5, the Court
issued an Order to Show Cause why defense counsel should not be sanctioned under
Federal Rule of Civil Procedure 11. Between the time the Court issued the Order to
Show Cause and the hearing date, defense counsel also moved for leave to file a
substitute pleading to replace the brief that included hallucinated citations, in
addition to responding to the Rule to Show Cause in writing. From the time they
received the Order to Show Cause, the City Attorneys have taken full responsibility
for the improper use of A.I. that led to the hallucinated case citations. On March 19,
the attorneys for the City of New Orleans who had signed the motion, Jalen Harris,
James Roquemore, Corwin St. Raymond, and Charline Gipson, appeared before the
Court for the Show Cause hearing.
LEGAL STANDARD
Rule 11 of the Federal Rules of Civil Procedure requires that “at least one
attorney of record” or an unrepresented party must sign “[e]very pleading, written
motion, and other paper” filed with a federal court. Fed. R. Civ. P. 11. Further, Rule
11 explains what an attorney represents to the court when s/he signs a filing and
provides for sanctions when a party violates the rule. In relevant part, Rule 11(b)
reads as follows:
(b) Representations to the Court. By presenting to the court a
pleading, written motion, or other paper—whether by signing, filing,
submitting, or later advocating it—an attorney or unrepresented party
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certifies that to the best of the person’s knowledge, information, and
belief, formed after an inquiry reasonable under the circumstances:
* * *
(2) 	the 	claims, 	defenses, 	and 	other 	legal 	contentions 	are
warranted by existing law or by a nonfrivolous argument for
extending, modifying, or reversing existing law or for establishing
new law . . . .
Fed. R. Civ. P. 11(b).
The affirmative duties imposed by Rule 11 apply to all pleadings, written
motions, and other papers submitted to a court. See Fed. R. Civ. P. 11(a); Thomas v.
Capital Sec. Servs., 836 F.2d 866, 870 (5th Cir. 1988) (en banc). Thus, when a litigant
files a pleading or motion, he certifies that he has conducted a reasonable inquiry into
both the facts and the law contained in the filing, and that to the best of his
knowledge, information, and belief, the pleading, written motion, or other paper has
adequate legal and factual support. See Fed. R. Civ. P. 11(b); Childs v. State Farm
Mut. Auto. Ins. Co., 29 F.3d 1018, 1023–24 (5th Cir. 1994).
In determining whether a litigant has violated Rule 11, courts apply an
objective (rather than subjective) standard of reasonableness. See id. at 1024 (citing
United States v. Alexander, 981 F.2d 250, 252 (5th Cir. 1993)). The conduct of the
litigant is assessed at the time he submitted the offending pleading or motion. Id.; see
also Thomas, 836 F.2d at 874–75 (citing Fed. R. Civ. P. 11 Advisory Comm. Notes).
Rule 11 also authorizes the court, on its own initiative, to “impose an appropriate
sanction on any attorney, law firm, or party that violated the rule or is responsible
for the violation” when “after notice and a reasonable opportunity to respond, the
court determines that Rule 11(b) has been violated.” Fed. R. Civ. P. 11(c)(1), (c)(3).
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DISCUSSION
At the Show Cause Hearing on March 19, Jalen Harris acknowledged that he
was 	the 	attorney 	who 	was 	primarily 	responsible 	for 	drafting 	the 	offending
memorandum. He explained that when he started to outline the brief, he wanted to
find cases from federal courts in Louisiana to support his legal propositions. Mr.
Harris began by searching for relevant cases on Westlaw but admitted that he
eventually resorted to ChatGPT. Mr. Harris took full responsibility for his misuse of
generative A.I. and conceded that he did not check the citations that ChatGPT had
provided, nor did he attempt to read the nine hallucinated cases that he cited in the
brief. Mr. Harris is a young attorney who has been with the City Attorney’s office
since 2024. He appeared genuinely contrite and apologized to the Court more than
once, in addition to assuring the Court that he would never make this mistake again.
Using ChatGPT and failing to check the case citations it provides constitute not only
a lapse in professional judgment, but also a violation of Federal Rule of Civil
Procedure 11. Furthermore, Rule 11 implicitly requires that attorneys read the cases
they cite in court filings to determine whether their arguments are supported by law.
Applying an objective standard of reasonableness, the Court concludes that Mr.
Harris undoubtedly violated this rule. That being said, the Court was also impressed
by the forthright way in which Mr. Harris accepted accountability for his conduct.
Next, the Court heard from James Roquemore, who also apologized to the
Court. Mr. Roquemore explained that as Mr. Harris’s immediate supervisor, he
reviewed Mr. Harris’s brief before it was filed and made substantial revisions to other
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sections of the memorandum. Mr. Roquemore acknowledged that he should have
inquired further about the hallucinated cases cited in the memorandum, particularly
because of the unusual formatting (the hallucinated cases were presented in bullet
points), but he admitted that he failed to do so. Mr. Roquemore is a Deputy City
Attorney, and as a supervising attorney, Mr. Roquemore has the important duty of
ensuring that he and the attorneys who report to him read each cited case and check
every citation before filing a motion or other pleading with a court. Moreover, Mr.
Roquemore has been practicing law for roughly thirty years. Due to both his
supervisory role and his extensive experience in the practice of law, the Court finds
that he bears more responsibility for the violation of Rule 11 than Mr. Harris does.
The Court also heard from Mr. St. Raymond, Chief Deputy City Attorney, and
newly appointed City Attorney Charline Gipson. First, it is important to note that
Ms. Gipson was not enrolled in this case when the motion at issue was filed, and in
fact, she was not sworn in to her new role as City Attorney until January 12, 2026,
only three days before Defendants’ motion was filed. The Court ordered her to appear
because as City Attorney, her name was in the signature block on the pleading, and
the Court wanted to find out how her office intended to address the now endemic and
nationwide problem of attorneys’ improper use of A.I.
Both Mr. St. Raymond and City Attorney Gipson outlined the actions the City
Attorney’s Office has taken to combat the future misuse of A.I. Specifically, the City
Attorney’s Litigation Division called a department-wide meeting immediately after
the Court issued the Order to Show Cause in this matter, and Ms. Gipson and her
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staff are currently in the process of developing a written policy concerning the use of
generative A.I. in the City Attorney’s Office. Further, Mr. Harris and Mr. Roquemore
attended a Thomson Reuters seminar about proper and improper uses of A.I. in legal
practice. Ms. Gipson also emphasized the importance of reading every single case that
an attorney cites in a brief, and she discussed the importance not only of task
leadership, but also, and more importantly, of people leadership.
Finally, it also came to the Court’s attention on March 19 that Defendants had
not served any of the filed motions on pro se Plaintiff Daniel Gentry, who also
attended the hearing, nor had they filed certificates of service in the record. Based on
the Court’s order, Defendants served Mr. Gentry with all pending motions via email
and by U.S. mail and filed a certificate of service in the record promptly after the
hearing. (Rec. Doc. 23).
The Court acknowledges and appreciates the fact that the attorneys for
Defendants graciously took accountability for the offending pleading and that they
sincerely apologized to the Court. Furthermore, the Court recognizes that Mr. Harris
is a relatively new attorney and that his supervisors bear some responsibility for not
noticing the hallucinated citations, particularly considering that they were formatted
in bullet points. Rule 11 requires that the Court provide due process, or notice and a
hearing, before imposing sanctions for violations of Rule 11. Here, the Court issued
the Order to Show Cause, which constituted notice for the hearing that was held on
March 19. Therefore, the Court has complied with the due-process requirement and
finds that defense counsel in this case violated Rule 11.
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CONCLUSION
Accordingly,
IT IS HEREBY ORDERED that under Federal Rule of Civil Procedure Rule
11, Jalen Harris is personally sanctioned for his conduct in this case in the amount
of $250.00.
IT 	IS 	FURTHER 	ORDERED 	that 	James 	Roquemore 	is 	personally
sanctioned in the amount of $1,000.00.
IT IS FURTHER ORDERED that the sanctions are to be paid by 5:00 p.m.
on Wednesday, April 22, 2026, to
Clerk of Court
U.S. District Court for the Eastern District of Louisiana
500 Poydras Street, Room C151
New Orleans, Louisiana 70130
The Court has chosen not to impose a sanction on Corwin St. Raymond, but
this Order should serve as a formal admonishment concerning the improper use of
A.I. by the attorneys in his department.
New Orleans, Louisiana, this 20th day of March, 2026.
____________________________________
CARL J. BARBIER
UNITED STATES DISTRICT JUDGE
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