The Pulse
Arizona Judge Orders AI-Free Rewrite of 67-Page Complaint
U.S. District Judge Krissa M. Lanham dismissed Shelly George’s 67-page complaint against Agriculture Secretary Brooke L. Rollins and barred AI drafting in a revised filing. The October 6 order sets an October 19 deadline and requires disclo
AI.info Team · Written with AI ·
AI suspicion, but not a finding
A federal judge in Arizona has ordered Shelly George to draft her next court complaint without artificial intelligence, while describing the evidence for AI use in her existing filing as an appearance rather than a proven fact. The distinction matters: U.S. District Judge Krissa M. Lanham dismissed George’s 67-page complaint against Agriculture Secretary Brooke L. Rollins for obscuring the claims, then barred AI tools from the replacement complaint.
Lanham’s October 6 order says George filed 199 paragraphs on September 11 and that the complaint “appears to have been generated by artificial intelligence” because it resembles other AI-generated complaints the court has encountered. The order does not establish that AI drafted it. Its stated grounds for dismissal center on the document’s length, repetition, unclear claims and failure to provide a short, plain statement of the case.
“The complaint appears to have been generated by artificial intelligence (‘AI’) as it resembles other AI-generated complaints the court has encountered.”
Krissa M. Lanham, U.S. District Judge
199 paragraphs, unclear claims
The order says George’s complaint mixed descriptions of different legal claims without clearly identifying which ones she intended to pursue. Near its beginning, it said the case principally relied on Title VII’s anti-retaliation provision; later, it described a hostile-work-environment claim and combined the concepts as a “retaliatory hostile work environment.” The filing also discussed governing law and referred to exhibits that were not attached, according to the judge.
Lanham called the filing a “shotgun pleading,” citing the Ninth Circuit’s 2026 decision in Gibson v. City of Portland. The order says many factual allegations were not clearly connected to a particular cause of action and that the complaint failed to put each claim in a separate count. The court dismissed it under the principle that a pleading must give the opposing party and the court sufficient notice of the claims and their basis.
New complaint capped at 25 pages
George may amend her complaint, but the replacement must be no longer than 25 pages and must give a short, plain account of the relevant facts and identify the claims she wishes to pursue. The order requires her to draft the allegations herself, without AI tools, and sets October 19, 2026, as the filing deadline. If she does not file by then, the clerk must enter a dismissal with prejudice.
The judge also denied George’s request to file electronically. Those directions apply to this case and do not amount to a general ban on AI use in federal court filings. The order separately lays down disclosure and verification requirements for any party who uses generative AI in other filings in the case.
Disclosure rules cover other filings
For those other filings, a party using generative AI must attach a declaration disclosing that use and identifying any portions that incorporate AI output. The filer must also certify that, using independent judgment, they personally reviewed the document and verified its accuracy and compliance with Federal Rule of Civil Procedure 11.
The order warns that inaccurate or undisclosed AI output—including incorrect or nonexistent case citations—may lead to sanctions without further warning. It defines generative AI as large language models that accept user input and generate new content, and names ChatGPT, Claude, Copilot, DeepSeek, Google Gemini and Grok as examples. For George, however, the immediate requirement is narrower and explicit: file a personally drafted complaint of no more than 25 pages by October 19.