Woodward Harbor L.L.C., et al. v. City of Mandeville, et al.

CourtDistrict Court, E.D. Louisiana
DecidedMarch 5, 2026
Docket2:23-cv-05824
StatusUnknown

This text of Woodward Harbor L.L.C., et al. v. City of Mandeville, et al. (Woodward Harbor L.L.C., et al. v. City of Mandeville, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Woodward Harbor L.L.C., et al. v. City of Mandeville, et al., (E.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA WOODWARD HARBOR L.L.C., ET AL. CIVIL ACTION VERSUS NO. 23-5824 CITY OF MANDEVILLE, ET AL. SECTION “O”

ORDER AND REASONS The Court ordered Michael R. C. Riess, Johanna Elizabeth Lambert, John R. Walker, and Thomas H. Huval, counsel for Plaintiffs, to appear to show cause as to why they should not be sanctioned for failure to comply with Federal Rule of Civil Procedure 11(b)(2) by signing and filing a written opposition1 to Defendant’s motion

to dismiss that contained hallucinated case citations, incorrect quotations, and false summaries of cases and legal rules. The four attorneys appeared before the Court on Tuesday, February 24, 2026 at 10:00 a.m. I. BACKGROUND On June 3, 2025, attorneys Michael R. C. Riess and John R. Walker electronically signed and filed a joint opposition2 to Defendant City of Mandeville’s motion to dismiss. Johanna Elizabeth Lambert and Thomas Huval’s names were also

included in the signature blocks. The motion contained citations to at least eleven cases that either did not exist or were incorrectly summarized, relied on, or quoted from. Three days later, Defendant filed a reply brief3 specifically identifying multiple

1 ECF No. 97. 2 Id. 3 ECF No. 99. examples of non-existent caselaw in Plaintiffs’ opposition. Plaintiffs took no action in response to the reply brief: they did not withdraw their opposition, file a surreply, or otherwise contend with Defendant’s claim that they had cited fake authorities.4

On February 5, 2026, the Court issued an Order5 dismissing with prejudice Plaintiffs’ complaint for failure to state a claim upon which relief can be granted. The Court’s Order noted that Plaintiffs’ opposition to Defendant’s motion to dismiss contained numerous examples of non-existent case citations, which the Court concluded were likely hallucinated citations arising from Plaintiffs’ attorneys’ use of generative AI. The Court issued an Order6 to Show Cause requiring each of Plaintiffs’ attorneys whose names appeared on the brief to file into the record a formal

explanation of the presence of hallucinated and improper case citations. The Order also required the four attorneys to appear before the Court on February 24, 2026 at 10:00 a.m. The attorneys each filed responses7 to the Court’s Order that included declarations and affidavits explaining the presence of hallucinated case citations in the opposition. In his declaration,8 John R. Walker of Jones Fussell, LLP, confirmed

that he alone was responsible for preparing and filing the joint opposition to the motion to dismiss. Mr. Walker admitted to having used generative AI tools to assist

4 All four attorneys claimed not to have read the reply brief. Mr. Walker stated that he reviewed the reply (but not closely) and ultimately did not see Defendant’s allegations regarding the false citations. Clearly, Defendant’s reply brief should have alerted Plaintiffs’ attorneys to the potential errors within their opposition and thereby prompted Plaintiffs to address the matter with the Court immediately and proactively. 5 ECF No. 101. 6 ECF No. 103. 7 ECF Nos. 104, 105, 106. 8 ECF No. 104-1. in drafting the motion, but claimed he was new to using AI tools and unaware that the tools could generate false case citations. Mr. Walker took full responsibility for the presence of hallucinated citations in the opposition. He averred that his law

partner at Jones Fussell, Mr. Huval, was on vacation without cellular service or internet access when drafts of the motion were circulated.9 Mr. Walker had no expectation that Mr. Huval would review the motion before it was filed.10 He also acknowledged that while he forwarded drafts of the motion to co-counsel Mr. Riess and Ms. Lambert of Riess LeMieux LLC, the group understood that the responsibility for verifying the accuracy of the motion lay entirely with Mr. Walker.11 Mr. Huval’s, Mr. Riess’s, and Ms. Lambert’s declarations and affidavits agreed with this version

of events.12 Each attorney was forthright in acknowledging the errors and apologizing to the Court.13 On February 24, 2026, the Court held a show-cause hearing to determine whether sanctions under Fed. R. Civ. P. Rule 11(b) were warranted in this matter.14 II. LEGAL STANDARD Federal Rule of Civil Procedure 11 governs the signing of pleadings, motions,

and other papers, representations to the Court, and sanctions. Rule 11(b) states that (b) By presenting to the court a pleading, written motion, or other paper—whether by signing, filing, submitting, or later advocating it— an attorney or unrepresented party certifies that to the best of the 9 Id. 10 Id. 11 Id. 12 ECF Nos. 105-1, 106-2, 106-3. In addition to submitting their affidavits, Mr. Riess and Ms. Lambert retained outside law firm Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, to prepare a formal response to the Court’s show-cause order. ECF No. 106. 13 ECF Nos. 104-1, 105-1, 106-2, 106-3. 14 ECF No. 110. person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances: . . .

(2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law[.]

Pursuant to Rule 11(c)(1), “If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation.” In determining whether an attorney has complied with Rule 11, the standard under which he is judged is “an objective, not a subjective, standard of reasonableness.” Snow Ingredients, Inc. v. Snowizard, Inc., 833 F.3d 512, 528 (5th Cir. 2016) (citing Whitehead v. Food Max of Miss., Inc., 332 F.3d 796, 802 (5th Cir. 2003)). “‘[T]he central purpose of Rule 11 is to deter baseless filings in district court and thus . . . streamline the administration and procedure of the federal courts.” Cordova v. Univ. Hosp. & Clinics, Inc., 92 F.4th 266, 273 (5th Cir. 2024) (quoting Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990)). A lawyer who signs a brief “violates Rule 11 if he fails to conduct a reasonable inquiry into the law and facts underlying his motion[.]” Walker v. City of Bogalusa, 168 F.3d 237, 241 (5th Cir. 1999). “[A] litigant’s obligations with respect to the contents of these papers are not measured solely as of the time they are filed with or submitted to the court, but include reaffirming to the court and advocating positions contained in those pleadings and motions after learning that they cease to have any merit.” FED. R. CIV. P. 11 Advisory Committee Note to 1993 Amendment. “An attorney’s good faith is [not] enough to protect [her] from Rule 11 sanctions.” Childs v. State Farm Mut. Auto. Ins. Co., 29 F.3d 1018, 1024 (5th Cir. 1994).

III. ANALYSIS The problem of AI-fabricated case citations is well-documented throughout the judiciary, including in this circuit. See, e.g., Fletcher v. Experian Info.

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Related

Walker v. City of Bogalusa
168 F.3d 237 (Fifth Circuit, 1999)
Jenkins v. Methodist Hospitals of Dallas, Inc.
478 F.3d 255 (Fifth Circuit, 2007)
Cooter & Gell v. Hartmarx Corp.
496 U.S. 384 (Supreme Court, 1990)
Snow Ingredients, Incorporated v. SnoWizard
833 F.3d 512 (Fifth Circuit, 2016)
Park v. Kim
91 F.4th 610 (Second Circuit, 2024)
Cordova v. Univ Hosp & Clinics
92 F.4th 266 (Fifth Circuit, 2024)

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Woodward Harbor L.L.C., et al. v. City of Mandeville, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/woodward-harbor-llc-et-al-v-city-of-mandeville-et-al-laed-2026.