Was Loftong v. Grove Farms sanctioned over AI-generated citations?

Loftong v. Grove Farms (Cir. Ct., DeSoto County, Miss., September 26, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: AI-hallucination sanction: $7,472 to opposing counsel, 6 hours AI CLE, bar referral (separate $37,584.91 discovery-abuse award not AI-related). $7,472 in monetary penalties.

Which AI tool was involved in Loftong v. Grove Farms?

The order in Loftong v. Grove Farms does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

September 26, 2025 · AI sanctions database

Loftong v. Grove Farms

Loftong v. Grove Farms 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: Cir. Ct., DeSoto County, Miss.
Date: September 26, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: AI-hallucination sanction: $7,472 to opposing counsel, 6 hours AI CLE, bar referral (separate $37,584.91 discovery-abuse award not AI-related)
Penalty: $7,472 in monetary penalties.

FineBar referralProfessional sanction

What the record shows

Addressing Attorney Price's June 19, 2025 filing, the court found she relied almost exclusively on fourteen citations that were either nonexistent cases or cases not standing for the principle quoted, which she acknowledged were produced through an AI research tool accessed via FastCase. As an AI-specific sanction the court ordered Price to pay Briggs $7,472.00 in attorney's fees within 30 days, complete six hours of CLE on AI, send the order to the Mississippi Bar, and write her client. (A separate $37,584.91 award in the same order sanctioned unrelated discovery-abuse / fraudulent-document conduct, not the hallucinated cases.)

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 · Cir. Ct., DeSoto County, Miss.

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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