In re CorMedix Securities Litigation (Judge Neals)

What happened

On June 30, 2025, Judge Julien Xavier Neals docketed an opinion in In re CorMedix Inc. Securities Litigation, No. 2:21-cv-14020, denying the defendants' motion to dismiss a shareholder class action against the pharmaceutical company.

Andrew Lichtman of Willkie Farr & Gallagher wrote to the court to "bring to the court's attention a series of errors in the opinion—including three instances in which the outcomes of cases cited in the opinion were misstated." According to the ABA Journal, the letter also identified quotations attributed to decisions that do not contain them and statements wrongly attributed to the defendants.

What the court did

The opinion was withdrawn from the docket on July 23, 2025, as reported by the ABA Journal. No explanation was given at the time.

After Senator Chuck Grassley wrote to him in October 2025, Judge Neals responded by letter dated October 20, 2025. He stated that a law school intern working in chambers had used ChatGPT for legal research without authorization or disclosure, contrary to both chambers policy and the law school's policy. He described the docketed opinion as an early draft that had not gone through the standard review process, and wrote that it was "released in error – human error." He stated that appropriate action had been taken with respect to the intern. He reported that chambers had since adopted a written policy prohibiting the use of generative AI for opinion research and drafting, and had strengthened its multi-level review of opinions.

Where it stands

Legal databases including Justia and CourtListener still carry a June 30, 2025 opinion in the case denying the motion to dismiss. It could not be confirmed from the sources opened whether a corrected opinion has issued. A CorMedix filing with the Securities and Exchange Commission in August 2026 refers to "the resolution of the motion to dismiss in the Securities Class Action" without stating the result. No disciplinary action against the judge has been reported. The Senate inquiry this matter prompted is recorded separately in this section.

The obligation it engaged

The errors are the kind Clause 3 of the Expert Record Standard is written to prevent: case outcomes and quotations that entered the work on the authority of a chat system and were not confirmed against the decisions themselves. Clause 4 was engaged as well. Each error was checkable, and opposing counsel checked it within weeks.

The judge's account also bears on Clause 7. The use of the system was not disclosed within chambers or logged, so it came to light only after publication. A professional who supervises assistants carries the same exposure. An expert who uses a research assistant, human or automated, adopts that assistant's work when the report is signed, and a record of who produced each part is what allows it to be checked before that point.

Sources

• U.S. Senate (Sen. Grassley) · October 20, 2025
  Neals to Grassley re judiciary use of AI
• ABA Journal · July 24, 2025
  Federal judge withdraws opinion after lawyer points out fake quotes, misstated case outcomes
• Justia · June 30, 2025
  In re CorMedix Inc. Securities Litigation, No. 2:21-cv-14020, Document 114

What could not be confirmed

Whether a replacement opinion was issued, and its date, could not be confirmed. The judge's letter gives July 22, 2025 as the date defense counsel identified the mistakes; the ABA Journal gives July 23, 2025 as the withdrawal date. Whether the Justia and CourtListener copies are the withdrawn text or a later version was not determined.