Lawyers' Bar Journal Article Discussing Their AI-Hallucination Errors Doesn't Entirely Satisfy Judge, but …
In *Doe v. Univ. of N.C. Sys.*, Chief Judge Martin Reidlinger criticized a North Carolina State Bar Journal article by Plaintiff's counsel Fred W. DeVore III and Rob Wilder for downplaying their AI-generated legal errors, which included fabricated citations and misquoted cases. The judge declined sanctions but expressed disappointment that the article failed to fully acknowledge the severity of the mistakes, including wasted court resources and undermined advocacy.
A North Carolina federal judge has criticized an article published by Plaintiff's counsel in the *North Carolina State Bar Journal* for not fully addressing their AI-related legal errors in *Doe v. Univ. of N.C. Sys.* The article, titled *Guarding Against AI Errors: Ethical Risks for NC Attorneys* and co-authored by Fred W. DeVore III and Rob Wilder, was intended to demonstrate remorse and educate other lawyers after the judge ordered them to explain why sanctions should not be imposed. In November 2025, the court ordered the Plaintiff's counsel to show cause for submitting documents with AI-generated errors, including nonexistent case citations, fabricated quotations, and misrepresented legal holdings. During a hearing, the lawyers admitted the mistakes stemmed from improper AI use and a failure to verify outputs, despite signing certifications confirming they had reviewed all submissions. The court agreed to hold off on sanctions pending the publication of the bar journal article, which they described as a warning to others about AI misuse. Judge Martin Reidlinger, however, found the article insufficient, stating it understated the scope of the errors. The lawyers had filed five flawed documents—two motion briefs and three opposition briefs—with citation mistakes that forced them to shift focus in reply briefs rather than advance their client’s case. The judge noted these errors wasted court resources and damaged the lawyers’ credibility but were not fully acknowledged in the article. The court emphasized that the article’s purpose—to prevent others from repeating the same mistakes—required a full account of the pitfalls. Instead, the piece fell short by failing to address the broader impact of the errors on litigation and the legal profession. While the judge declined to impose sanctions, citing the lawyers’ good-faith repentance, he expressed disappointment that the article did not meet the court’s expectations for transparency and educational value. The ruling underscores growing concerns about AI misuse in legal practice, where errors can undermine justice and waste judicial resources. The case highlights the need for lawyers to critically assess AI-generated content and take full responsibility for its accuracy, even when mistakes occur.
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