Was Smith v. Athena Construction Group, Inc. sanctioned over AI-generated citations?

Smith v. Athena Construction Group, Inc. (D.D.C., October 3, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Section 1927 sanction: counsel ordered to pay defense fees/costs (amount to be set); counsel self-reported to Pennsylvania Bar. No monetary penalty in this order.

Which AI tool was involved in Smith v. Athena Construction Group, Inc.?

The order in Smith v. Athena Construction Group, Inc. does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

October 3, 2025 · AI sanctions database

Smith v. Athena Construction Group, Inc.

Smith v. Athena Construction Group, Inc. 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.D.C.
Date: October 3, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Section 1927 sanction: counsel ordered to pay defense fees/costs (amount to be set); counsel self-reported to Pennsylvania Bar
Penalty: No monetary penalty in this order.

Professional sanction

What the record shows

Following a show-cause order, the court found that of the nine cases cited in counsel's Opposition Brief, four were cited for a false proposition, four had fabricated quotations, and one was a nonexistent case with a fabricated quotation. Counsel Glenn Ellis took responsibility and stated he used an AI legal research tool without checking the citations. Finding the conduct reckless and singularly egregious under 28 U.S.C. section 1927, the court ordered Ellis to pay the attorney's fees and costs for the continuance motion and reply, with the final amount to be entered after defendants submit an invoice; the court declined to make a new bar referral because Ellis had already self-reported to the Pennsylvania Bar.

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.D.C.

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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