A federal judge formally reprimanded—without imposing penalties—a former Justice Department attorney for abusing the judicial process by knowingly filing an AI-generated brief with fabrications and lacking candor about it at an ensuing hearing under oath.
“Serious sanctions would ordinarily be justified to vindicate the integrity of the judicial process and deter similar conduct,” said Magistrate Judge Robert T. Numbers of the Eastern District of North Carolina in a Tuesday order. “But in light of the professional consequences he has already suffered, the Court will limit its sanction to a public reprimand.”
The Raleigh-based assistant US attorney, Rudy Renfer, was fired in March over the AI errors in a civil case before he had a chance to resign, the district’s US Attorney W. Ellis Boyle said at the time, although Renfer said at the hearing that he chose to quit.
Judge Numbers already chastised Renfer in person about the false quotes and erroneous citations at a court-ordered show cause hearing March 10. But the new order goes further by criticizing Renfer for providing testimony at the hearing that withheld his use of AI in drafting the brief.
Only upon questioning from the court did Renfer acknowledge that he “panicked” and “used artificial intelligence to” catch up after inadvertently saving over his draft.
Renfer contended that he unintentionally submitted the error-laden brief before checking it for accuracy, a claim Numbers said “does not stand up to scrutiny.”
“It is, at this time, foreseeable that generative AI tools will provide fabricated legal authority when asked to engage in legal analysis. Renfer cannot avoid the consequences of his failure to account for that reality,” Numbers said.
Although the judge went on to call the conduct “particularly odious” due to it coming from someone holding an immensely trusted position of assistant US attorney, he ultimately concluded that Renfer’s reputational and financial losses from losing his job don’t necessitate additional fines.
The case is Fivehouse v. DOD, E.D.N.C., No. 2:25-cv-00041.
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