A lawyer who sued Sean “Diddy” Combs is facing a judge’s wrath after he used artificial intelligence and cited “hallucinated case law” in court filings — and it’s not the first time.
In a ruling Tuesday (Dec. 16), Judge Leo Gordon sharply criticized Tyrone Blackburn after the lawyer admitted he “fabricated legal propositions derived from generative artificial intelligence” during the case, which he filed against Combs on behalf of alleged victim Liza Gardner.
“Mr. Blackburn confirmed that he indeed used AI that provided him with hallucinated case law and propositions that he then incorporated into his response brief and that he failed to verify on subsequent review,” the judge wrote. “Despite multiple forms of notice and warning, proper verification did not occur here.”
The judge ordered Blackburn to pay a $6,000 fine, but the more serious penalty was non-monetary: He must alert the bar associations in both New York and New Jersey about the AI mishap, so that those groups can “take whatever action they deem appropriate.”
AI has become a major tool for lawyers — and a major problem for some of them. AI models often convincingly spit out false information, and lawyers have repeatedly been penalized for failing to catch them. In one high-profile case earlier this year, a Wyoming federal judge punished two lawyers from personal injury firm Morgan & Morgan for citing AI-fabricated cases in a lawsuit against Walmart.
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Blackburn, a New York attorney who has filed many eyebrow-raising cases in recent years, has already faced similar AI-related censure. In June, a federal judge threatened sanctions after he filed a motion containing “non-existent quotations” and other AI-generated errors — and then did so again in a brief defending his conduct: “The court views Blackburn’s conduct as a clear ethical violation of the highest order,” the judge wrote.
Lawyers for Fat Joe, facing Blackburn in another lawsuit, have accused him of sloppily using AI in that case, too — claiming to have found “at least ten instances” of such problems. After Blackburn blamed the problem on AI-powered research tools offered by LexisNexis, the legal research giant itself responded that such claims were “misleading” and that Blackburn “never an authorized user or subscriber” of such tools.
AI mishaps have already repeatedly cropped up in other music cases. In 2023, convicted ex-Fugees rapper Pras Michel accused his lawyer of botching his criminal trial partly because he relied on AI to help craft his closing arguments. And in May, an attorney from the prestigious firm Latham & Watkins apologized after an AI model created a fake footnote for a real source — a misstep that, ironically, came in a brief filed on behalf of AI firm Anthropic in its battle with music publishers.
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In the Gardner case, Blackburn repeatedly cited a case called “United States v. Masha,” claiming it was a 2021 ruling by a federal appeals court. But the case doesn’t exist, which Blackburn later acknowledged after it was flagged by defense counsel. He later apologized, saying he took “full responsibility for this error.” But for Judge Gordon, that was not enough.
“Mr. Blackburn’s admission of responsibility and remorse expressed … do not completely excuse his lack of diligence, especially in light of the pattern behavior identified,” the judge wrote, referring to previous discipline in other cases, including the previous AI problem.
For Blackburn, the punishment might be the least his problems. In June, he was arrested for allegedly hitting Fat Joe’s process server with his car “in a failed attempt to avoid being served” with the lawsuit. He was indicted in October and the case against him remains pending.
