VERITAS
March 10, 2026 · AI sanctions database

United States of America v. Lorenzio Reshaud Simmons

United States of America v. Lorenzio Reshaud Simmons 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
E.D. North Carolina
Date
March 10, 2026
Party
Lawyer
AI tool
Not identified in the order
Outcome
Warning; corrected brief permitted
Penalty
No monetary penalty in this order.
Warning

What the record shows

The court found defendant's sentencing memorandum bore the hallmarks of AI generation, identifying eleven examples including 'United States v. Hazel, 696 F.3d 473, 478 (4th Cir. 2012),' for which there is no such Fourth Circuit case (a similarly named Sixth Circuit case from a different year exists), plus quotations attributed to cases that do not contain them. Defense counsel acknowledged the errors and her AI use.

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 · E.D. North Carolina