Which AI tool was involved in Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law, PLLC?

The matter records Protégé (LexisNexis) as the generative tool associated with the unverified citations in Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law, PLLC.

March 10, 2026 · AI sanctions database

Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law, PLLC

Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law, PLLC is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: S.D. New York
Date: March 10, 2026
Party: Lawyer
AI tool: Protégé (LexisNexis)
Outcome: Admonishment; warning of future sanctions/referral
Penalty: No monetary penalty in this order.

WarningAlleged

What the record shows

The court addressed attorney Tyrone Blackburn's pervasive citations to non-existent authority and misstatements of law in his motion-to-dismiss briefing. Blackburn attributed the miscited cases to the AI tool 'Protege' within LexisNexis, but LexisNexis stated he had no subscription to its AI tools, raising the court's concern about misrepresentation of the research source. The court declined to strike the submissions or award fees but warned that further misconduct could lead to sanctions or a disciplinary referral.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · S.D. New York

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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