Maine Lawyer Sanctioned Over AI Errors in Court Filings

Judge Stacey D. Neumann of the federal court in Portland sanctioned Kelly Guagenty, a partner at the Massachusetts law firm Justice Law Collaborative. The underlying civil lawsuit continues.

In briefs filed in an abuse and forced labor lawsuit related to Hyde School, nonexistent case citations, mistranslated case descriptions, incorrect quotations, and misattributions appeared, and the court viewed this as the result of AI use combined with inadequate verification.

Instead of a fine, the court ordered the following measures:

• Completion of AI-related CLE
• Establishment of a verification process for future filings

Because Guagenty acknowledged responsibility and showed remorse, no additional monetary sanctions were imposed.

Maine's rules do not separately address AI, but lawyers are obligated to maintain up-to-date understanding of technological change and to independently verify their work. Some states already require disclosure of AI use, and the ABA holds that blindly trusting an AI draft can undermine the duty of competent representation.

A database maintained by Damien Charlotin at HEC Paris has tracked about 1,400 AI-related citation error sanctions worldwide since April 2023, most of them in the United States. Of these, 3 out of every 5 involved pro se litigants rather than lawyers.

The Maine Bar Association regularly holds CLE sessions on topics including AI basics, AI impersonation, trademark law, and the use of AI in discovery.