Raul Gonzales Davila v. Roblen, LLC f/d/b/a Vicolo Pizza Restaurant and Viktor Berisha

Summary

The United States District Court for the District of Connecticut considered sanctions arising from plaintiff's counsel's submission of a brief containing fabricated AI-generated quotations from legal authorities. The court ordered David Stich to complete at least three hours of continuing legal education on responsible AI use and share his knowledge with the Connecticut legal community. The court declined to impose sanctions on co-counsel Stephanie Stich.

Holdings

1. David Stich's failure to review AI-generated quotations and citations before filing a brief, resulting in arguments based on fabricated law, constituted a negligent failure to perform his responsibilities as an officer of the court and warranted sanctions under the court's inherent authority.
2. Bad faith was not required because David Stich's conduct involved a negligent failure to perform his responsibilities as an officer of the court and was not integrally related to legitimate zealous advocacy.
3. Stephanie Stich was not sanctioned because, although she was not entirely candid about the reason for seeking to file a corrected brief, she did not lie, deceive the court, or make a false statement of fact or law under Connecticut Rule of Professional Conduct 3.3.

Questions Presented

1. Whether David Stich's filing of a brief containing fabricated AI-generated quotations, without reviewing the cited authorities, warranted sanctions under the court's inherent authority.
2. Whether the court was required to find bad faith before sanctioning David Stich's negligent or reckless failure to perform his responsibilities as an officer of the court.
3. Whether Stephanie Stich's failure to disclose the reason for seeking to file a corrected brief violated the duty of candor to the tribunal or otherwise warranted sanctions.

Disposition

other