U.S. Magistrate Judge Jennifer Willis of the Southern District of New York issued an order on Friday rebuking attorney Tyrone Blackburn for allegedly including artificial intelligence-fabricated quotations in a court filing. The filing was part of a lawsuit brought by Blackburn on behalf of performer Terrance Dixon against the entertainment company Roc Nation and musician Fat Joe.
In her order, Judge Willis stated that Blackburn's filing contained quotations that were not present in the legal cases cited. This follows previous sanctions against Blackburn in other jurisdictions: a federal court in New Jersey sanctioned him in December for citing nonexistent cases, and a federal judge in Pennsylvania fined him $5,000 last year for similar conduct.
Blackburn stated on Monday that he would respond to the court's order but denied relying on fabricated case law. In a July 7 filing, he argued that while he paraphrased some material, the decisions cited were "real, published, binding authority." Roc Nation and its counsel at Quinn Emanuel had previously moved to strike the filing, citing "AI-hallucinated citations."
The underlying lawsuit involves allegations of employment-related misconduct and lost wages filed by Dixon against Roc Nation and Fat Joe. Both defendants have denied the allegations. Under current legal guidelines, lawyers are permitted to use AI tools but remain responsible for verify the accuracy and authenticity of all citations in their court submissions.