Was McCarthy v. DEA sanctioned over AI-generated citations?

McCarthy v. DEA (3rd Circuit CA, March 27, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Public reprimand of counsel (Daniel A. Pallen), with notice to other courts and disciplinary authorities; no monetary sanction.. No monetary penalty in this order.

Which AI tool was involved in McCarthy v. DEA?

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

March 27, 2026 · AI sanctions database

McCarthy v. DEA

McCarthy v. DEA 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: 3rd Circuit CA
Date: March 27, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Public reprimand of counsel (Daniel A. Pallen), with notice to other courts and disciplinary authorities; no monetary sanction.
Penalty: No monetary penalty in this order.

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What the record shows

In a precedential opinion, the Third Circuit found that counsel violated the duty of competence by filing a brief in which seven of eight cited authorities were inaccurately described and one did not exist, relying on unverified AI-generated summaries. The court imposed a public reprimand with notice to other courts and disciplinary authorities, declining a monetary sanction only because this was the first Third Circuit case addressing the issue and warning that future offenders may face harsher penalties.

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 ↗ · CourtListener record ↗

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 · 3rd Circuit CA

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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