Texas Attorney Sanctioned Over AI-Generated Citations in Filing

According to Bloomberg Law, a Texas attorney was sanctioned for including inaccurate citations generated by artificial intelligence in a motion filing, according to a Texas state judge.

Lawrence Chang must pay $2,000 in attorneys’ fees and expenses to opposing counsel at Rusty Hardin & Associates LLP and write a letter outlining where his AI use erred and how he’ll avoid doing so in the future, Judge Maya Guerra Gamble said in an order Wednesday. Guerra Gamble granted the opposing counsel’s motion to sanction Chang, who works for Choate & Associates PC.

The court finds “good cause supports the imposition of sanctions in order to deter such conduct in the future, which amounts to serious misconduct that threatens to impugn the integrity of the courts and the administration of justice,” Guerra Gamble said.

Chang represents an acupuncture business alleging legal malpractice claims against prominent Texas attorney Dan Cogdell. The business alleges Cogdell never got permission to negotiate a $2.3 million settlement with the federal government to resolve claims they over billed the US Department of Veteran Affairs.

The sanctioned attorney admitted to using AI and not checking the veracity of the citations it spit out in a Sept. 23 filing. Chang mistakenly initially blamed the error on an “over-reliance” on a research tool in WestLaw but later realized it stemmed from pasting his draft into ChatGPT’s legal tool to improve his writing, the attorney said.

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