Was Jessica Fuller v. Hyde School, et al. sanctioned over AI-generated citations?

Jessica Fuller v. Hyde School, et al. (D. Maine, May 5, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Non-monetary sanctions: AI CLE course and firm procedures. No monetary penalty in this order.

Which AI tool was involved in Jessica Fuller v. Hyde School, et al.?

The matter records ChatGPT as the generative tool associated with the unverified citations in Jessica Fuller v. Hyde School, et al..

May 5, 2026 · AI sanctions database

Jessica Fuller v. Hyde School, et al.

Jessica Fuller v. Hyde School, et al. 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: D. Maine
Date: May 5, 2026
Party: Lawyer
AI tool: ChatGPT
Outcome: Non-monetary sanctions: AI CLE course and firm procedures
Penalty: No monetary penalty in this order.

Professional sanction

What the record shows

Plaintiff's counsel Attorney Kelly Guagenty disclosed that she or a team member used AI (either Claude or ChatGPT) in drafting two filings and that she had not conducted a line-by-line citation check; the Court found the filings contained citations the defendants characterized as inaccurate, misleading, and potentially fabricated. The Court imposed non-monetary sanctions, ordering counsel to complete a CLE course on generative AI and to create firm procedures to prevent recurrence.

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 · D. Maine

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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