“Applying the framework discussed above, the Court finds that the first factor—verification and inquiry—weighs in favor of sanctions because Attorney Miller failed to conduct a reasonable human verification of the authorities cited in the challenged filings before submitting them.”
The file →
- Barteca Holdings v. Tacobarn Newtown involved defense attorney Hilary B. Miller.
- Miller submitted two motions containing 16 errors in citations, quotations, and rules from unverified AI research.
- The court imposed a $3,500 fine and referred the attorney to the court's Grievance Committee.
- The case was before the U.S. District Court for the District of Connecticut.
- On August 4, 2026, Judge Vernon D. Oliver found Miller violated Rule 11 after using Claude, OpenLaw, and ChatGPT.