Aguilar v. The Crawford Group, Inc.

What happened

Aguilar v. The Crawford Group, Inc., No. 1:25-cv-12395-AK, is a civil action in the District of Massachusetts against a group of insurers, rental-car entities and others. The plaintiff was represented by local counsel and by Blake Lindemann, a California attorney admitted pro hac vice, meaning admitted for this case only.

Lindemann filed three oppositions. The Enterprise defendants identified errors in them and moved for Rule 11 sanctions, and the court ordered him to show cause. The order describes what it found. In the opposition to the motion to strike, "approximately half of the citations in Lindemann's memorandum of law contain an error." The only case cited for one argument, Rodriguez v. Doral Mortgage Corp., "never mentions Rule 12," the rule the argument was about. The brief also cited at least five cases for quotations they do not contain and included a fictitious Westlaw citation.

In his response of April 11, 2026, Lindemann corrected only some errors and called the rest typographical. The order records that he "admitted to using AI to draft the Strike Opposition, explaining that he believed that the enterprise-level version of AI software he was using did not hallucinate cases."

What the court did

On September 25, 2026, Judge Angel Kelley granted the motion and also imposed sanctions on the court's own initiative under Rule 11. The order states: "There is no rule against the use of AI in researching and drafting legal papers, but it must be utilized responsibly." It declined Lindemann's request for another chance to correct the errors, finding that he had "demonstrated either unwillingness or inability to confirm the legal authority upon which he relies."

The sanctions are two. The Lindemann Law Firm must pay the Enterprise defendants' reasonable fees and costs for three filings, which "shall not exceed $10,000." And "The Court revokes Attorney Lindemann's pro hac vice status," leaving local counsel in the case. The court declined to sanction errors in briefs answering other defendants, whose errors it described as less severe and who had not moved for sanctions.

Where it stands

The parties were directed to file a joint notice on fees by October 23, 2026, and a status conference is set for November 9, 2026. No appeal was located as of October 8, 2026.

Aguilar v. Crawford Group is the clearest instance in this record of a lawyer relying on the premise that a paid, enterprise version of a tool would not fabricate. Revocation of pro hac vice admission also appears in other matters, but here it rested on the repeated failure to correct after warning, the same factor the Solicitors Disciplinary Tribunal weighed in SRA v Kumar.

The obligation it engaged

Clause 3 of the Standard, independent authority, is engaged by every miscited case. Clause 4, checkability before adoption, is engaged by the premise itself. The Standard asks the user to identify, before adopting output, what it will be checked against. A belief that a product tier does not err is the absence of that step, and it is a belief an opposing expert will test.

An expert using an enterprise or legal-specific system should expect the same question at deposition: what did you check the output against, and where is the record of the check.

Sources

• U.S. District Court, D. Mass. (copy hosted for the AI Hallucination Cases database) · September 25, 2026
  Memorandum and Order on Motion for Sanctions (ECF 155)

What could not be confirmed

The AI product is not named in the order. No press coverage was located. Whether fees were agreed was not known as of 2026-10-08.