The case of Aguilar v. Crawford Group, Inc., No. 25-CV-12395-AK (D. Mass. Sept. 25, 2026) (Kelley, J.) presents another sanctions decision where an attorney used fake citations to fake cases.

Memorandum and Order on Motion for Sanctions. The court granted the motion and imposed Rule 11 sanctions on pro hac vice counsel Blake Lindemann because of the use of hallucinated citations. Local counsel avoided sanctions.

Facts of the Underlying Case

The case arises from a 2019 car crash. Sean St. Louis was driving a car that Shauna McCormick had rented from Enterprise Rent-A-Car. He collided with another vehicle and killed its backseat passenger, Maryori Conde. St. Louis also died in the crash.

Conde’s representative, Rosario Aguilar, sued in Massachusetts state court. She won a $3,260,880.33 judgment against McCormick. The state court dismissed the claims against the Enterprise entities on summary judgment.

To collect on the McCormick judgment, Aguilar filed this second action in Massachusetts Superior Court on August 27, 2025. She sought insurance coverage from the Enterprise Defendants’ insurers and sued St. Louis’s estate for negligence. Two days later, the Enterprise Defendants removed the case to federal court.

Procedural History: What Lindemann Did

Appearance (Sept. 4, 2025). Attorney Austin Dana appeared as local counsel. Lindemann, who is admitted in California, was admitted pro hac vice the same day.

Pleading maneuvers (Oct.–Nov. 2025).

• The Crawford Group moved to dismiss on September 30. The parties agreed to extend Plaintiff’s response deadline to October 28.
• On October 27, Lindemann moved for a second extension, to November 17.
• The next day, October 28, he filed an Amended Complaint instead.
• After the court granted the extension and denied the first motion to dismiss as moot, Lindemann filed a Second Amended Complaint on November 17, styled a “Renewed First Amended Complaint.” He did so without leave of court.

The Strike Opposition (Nov. 21, 2025). The Enterprise Defendants moved to strike the Second Amended Complaint because it was filed without leave. Within five hours, Lindemann filed a 20-page opposition (Dkt. 51), even though he had two weeks to respond. The court later found that about half of its citations contained errors:

• He cited Rodriguez v. Doral Mortgage Corp., 57 F.3d 1168 (1st Cir. 1995), six times. It was his only authority for the claim that Rule 12(g)(2) barred further Rule 12 motions. Rodriguez never mentions Rule 12, and the proposition is legally wrong.
• He attributed a quotation to FDIC v. Jones using a fictitious Westlaw citation.
• He cited Henderson, Correa-Martinez, J&A Realty, and Glassman for propositions, standards, or quotations those cases do not contain.
• He altered a quotation from Love v. Michigan Property Resources without marking the changes, and mischaracterized its holding.
• He failed to attribute at least two quotations.
• He made significant unmarked alterations to quotations from Neilson, Hanley, and Karle.

The court rules first (Nov. 25, 2025). Before anyone discovered the citation problems, the court denied the motion to strike.

Unexplained withdrawal (Dec. 1, 2025). Six days after that ruling, Lindemann filed a one-sentence Notice of Withdrawal of the Strike Opposition. It gave no explanation and did not disclose the bad citations. He later attributed the delay to leaving for vacation right after filing.

Motion for Sanctions (Dec. 5, 2025). The Enterprise Defendants moved for sanctions under Rule 11, the court’s inherent power, and 28 U.S.C. § 1927. Before filing, they had emailed Lindemann about the errors.

More flawed briefs after notice. Four groups of defendants then moved to dismiss. Lindemann’s oppositions repeated the problem, even though he was by then on notice:

• Enterprise Opposition (Dkt. 97):
  • He again cited Rodriguez for the same Rule 12(g)(2) proposition.
  • He cited a nonexistent Dorchester Mutual case.
  • He asserted that defendants had cited Moore v. GEICO and Hertz Corp. v. Superior Court. They had not, and the citations given were fictitious.
• Travelers Opposition (Dkt. 93):
  • He gave an incorrect citation for Scottsdale Insurance.
  • He cited Green Mountain and Citizens Insurance for quotations they do not contain.
• Another opposition (Dkt. 94): He gave an incorrect citation for SAS International.

His opposition to sanctions (Dkt. 92). Lindemann argued four things:

1. The Rule 11 safe harbor barred sanctions.
2. The errors came from an earlier draft that was “inadvertently filed.” He never produced the supposedly correct final version.
3. The episode was an “isolated event.”
4. The Enterprise Defendants should themselves be sanctioned for allegedly concealing insurance coverage. He never filed a separate motion on this.

Order to Show Cause (Dkt. 126). The Enterprise Defendants’ reply identified further errors. The court independently found errors in the Travelers Opposition and ordered Lindemann to show cause as to all three briefs.

His response (Apr. 11, 2026, Dkt. 135).

• He corrected only three errors and called the rest “typographical.”
• For the first time, he admitted using AI to draft the Strike Opposition. He said he believed the enterprise-level AI tool he used did not hallucinate.
• He repeated the wrong-draft explanation and blamed his haste to file before vacation.
• He blamed the errors in the motion-to-dismiss oppositions on a prolonged bout of influenza. He had already received one extension for that illness and did not seek another.
• He acknowledged he was the sole attorney responsible.
• He said he had adopted citation-verification procedures. A later filing (Dkt. 141) added that he had voluntarily completed CLE on the ethical use of AI.
• Even his “corrected” Moore citation misstated the case’s subsequent history (n.5).

Merits disposition (Sept. 2, 2026). The court granted all four motions to dismiss. Only McCormick and St. Louis’s estate remain as defendants.

The Court’s Analysis

Safe harbor unavailable. Once a court has ruled on the challenged filing, it can no longer be withdrawn to avoid sanctions. Triantos v. Guaetta & Benson, LLC, 91 F.4th 556, 561 (1st Cir. 2024). The withdrawal came six days after the court ruled.

Procedure satisfied for all three briefs. The motion was filed separately and Lindemann had notice. The court’s show-cause order under Rule 11(c)(3) covered the two oppositions to the motions to dismiss.

Standard. The test is objective reasonableness; “culpably careless” conduct is enough. In re Ames, 993 F.3d 27, 34–35 (1st Cir. 2021). Bad faith is not required: “a pure heart no longer excuses an empty head.” Lancellotti v. Fay, 909 F.2d 15, 19 (1st Cir. 1990).

The Lawyer’s defenses are rejected.

1. All cases are real. False. In any event, a real citation attached to the wrong case or proposition has the same effect as a fake one.
2. Every proposition is sound. False. The Rodriguez proposition was wrong in two briefs.
3. He was candid. No. He spent five months obfuscating with the wrong-draft story before admitting fault.
4. It was carelessness, not bad faith. Bad faith is not required. Also, continuing to file flawed briefs after notice “indicates that this is not an instance of mere carelessness” (citing ByoPlanet, 792 F. Supp. 3d at 1354).

Whether AI was used is irrelevant. For the two later briefs, Lindemann never admitted using AI, and it did not matter: he failed to verify his citations either way. Not knowing that AI can hallucinate is no excuse (n.8).

Mitigation considered but insufficient. The court credited his verification procedures and CLE but held that deterrence still required sanctions.

Local counsel. Dana was not sanctioned because Lindemann admitted sole responsibility. The court reminded Dana of his duty to supervise pro hac vice counsel.

Sanctions Imposed

1. Fees. The Lindemann Law Firm must pay the Enterprise Defendants’ reasonable fees and costs, capped at $10,000. The award covers:
   • replying on the motion to strike,
   • the sanctions motion and its reply, and
   • replying on the motion to dismiss.
   The parties must confer and file a joint notice, or separate notices if they disagree, by October 23, 2026.
2. Pro hac vice revoked. Dana remains as counsel. A status conference is set for November 9, 2026.

No sanctions were imposed for the errors in the other defendants’ oppositions (n.6). The court also refused Lindemann’s request for another chance to find and correct his own errors (n.7).

Comments: Here the lawyer should have done a better job of owning his mistakes. To his credit he did not blame local counsel and took full responsibility for the errors.

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