Judge Spares Attorney Sanctions For ChatGPT Use in F-1 Visa Suit

A federal judge declined to impose sanctions on an immigration attorney on Thursday who admitted to using artificial intelligence in a filing that hallucinated a non-existent case citation.

Judge Amit P. Mehta vacated his order for Attorney Sarnata Reynolds with Ceartas Solutions to show cause and said he appreciates and credits her “candid and contrite” response on July 3. But, in the same minute order, Mehta admonished Reynolds’ use of AI, saying it’s “no substitute” for due diligence, and ordered her to inform another court about this matter should she ever commit a similar error.

• Reynolds represents Student Doe, who jointly dismissed his lawsuit against the Trump administration on June 30 after alleging his F-1 visa was unlawfully terminated in the Student and Exchange Visitor Information System
• The fictitious citation, Moms Against Poverty v. Department of State, was generated in Reynolds’ June 22 brief to demonstrate that Doe only needed to demonstrate a likelihood of jurisdiction to avoid dismissal
• Reynolds admitted to failing to verify the case and told Mehta that she “deeply regrets” the incident and asked to be spared of sanctions, according to her response brief

The case is Doe v. Noem, D.D.C., No. 1:25-cv-01352, minute order 7/10/25.

Seamus Hughes in Washington also contributed to this story.