TLDR: A Dallas attorney, Javier Perez, has been sanctioned by a Texas federal judge for failing to disclose his use of generative artificial intelligence (AI) in preparing a sworn declaration for a summary judgment response. The AI-generated content was found to be inaccurate and nonexistent, violating local civil rules and Federal Rule of Civil Procedure 11. The sanction requires Perez to reimburse opposing counsel for fees and complete two hours of AI-focused continuing legal education.
Dallas, Texas – A federal judge in the Northern District of Texas has issued sanctions against Dallas attorney Javier Perez for his undisclosed use of generative artificial intelligence (AI) in legal filings. The ruling, handed down by U.S. District Judge Ed Kinkeade, highlights the growing scrutiny on attorneys’ responsible use of AI tools in legal practice.
Perez was found to have violated a local civil rule (Northern District of Texas Local Civil Rule 7.2) mandating the disclosure of generative AI use, as well as Federal Rule of Civil Procedure 11, which requires factual contentions to have evidentiary support. The attorney admitted to using a popular AI chatbot, specifically ChatGPT, to prepare portions of his client’s sworn declaration. This declaration was submitted as part of the plaintiff’s response to a motion for summary judgment in the case of Wilson v. KIPP Texas Inc..
Judge Kinkeade emphasized that ‘even though artificial intelligence is a rapidly evolving technology, there have been enough repeated incidents of attorneys’ misuse of the technology that the pitfalls associated with using artificial intelligence are well-established.’ The court noted that by failing to disclose the use of ChatGPT, Perez implicitly certified that no generative AI was used, which was inaccurate. Furthermore, the AI-generated information within the sworn declaration was deemed ‘inaccurate and nonexistent,’ constituting a misrepresentation of facts to the court.
This case differs from previous AI-related sanctions where attorneys were penalized for submitting ‘hallucinated’ or nonexistent legal citations. Instead, Perez’s sanction stems from the creation of fabricated factual content, including ‘artificially generated ‘quotations’,’ within a sworn document.
As a result of the violations, Judge Kinkeade ordered Perez to reimburse KIPP Texas, a public charter school network, for the attorneys’ fees and associated costs incurred in preparing the summary judgment reply that exposed the inaccuracies. Additionally, Perez is required to complete two hours of continuing legal education focused on artificial intelligence by the end of February.
Perez is the sole attorney listed as representing the plaintiff, Dr. Joy Wilson, in the court docket. The plaintiff’s September 18 filing, titled ‘Plaintiff’s Notice Regarding Use of Generative Artificial Intelligence,’ further detailed the attorney’s admission.
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This sanction serves as a stark reminder to legal professionals about the critical importance of transparency and verification when integrating AI tools into their workflows, particularly concerning factual assertions and sworn statements.
