# Johnson v. Dunn: The Gap Where Rule 11 Does Not Reach

> Rule 11 does not apply to discovery motions. Johnson v. Dunn shows what a court does instead, and why having an AI policy counted against the lawyers.

[Home](https://rankshieldlegal.com/) / [Blog](https://rankshieldlegal.com/blog/) / Litigation & Evidence Inherent authority
# The Firm Had an AI Policy: Johnson v. Dunn and the Gap Where Rule 11 Does Not Reach
Most writing about AI sanctions assumes Rule 11 is the mechanism. In Johnson v. Dunn, the court found Rule 11 did not apply at all, because the filings were discovery motions and Rule 11(d) excepts them. It called that "an unintended anomaly," proceeded under its inherent authority instead, and imposed consequences no fine schedule would have produced. The lawyers involved worked at a large firm with AI policies, internal controls, and premium research databases. The court treated that as making things worse.

By [Jamie Kloncz](https://rankshieldlegal.com/about/), Founder, RankShield ** 22 min read ** Published August 30, 2026

Johnson v. Dunn, 792 F.Supp.3d 1241, was decided by the United States District Court for the Northern District of Alabama on July 23, 2025 [[1]](#ref-1). It is a prisoner civil rights action, and the sanctions arose from two discovery motions containing citations to authority that did not exist.
Two things make it worth reading closely more than a year later, and neither is the fact that a lawyer filed a fabricated citation. The first is doctrinal: the court held that Rule 11, the provision nearly every discussion of AI sanctions is built around, **did not apply**. The second is uncomfortable: the firm had done much of what this site and everyone else recommends, and the court counted that against the lawyers rather than for them.
On the first point the court was explicit. Because the motions at issue were discovery motions under Rules 30 and 37, Rule 11 "does not apply" by operation of Rule 11(d), which exempts motions under Rules 26 through 37 [[1]](#ref-1) [[2]](#ref-2). The court described this as "an unintended anomaly in Rule 11," noting that the advisory committee expected Rules 26 and 37 to cover such misconduct, but that those rules "furnish no basis for the court to address the false statements of law these attorneys made in discovery motions" [[1]](#ref-1) [[3]](#ref-3).
On the second, the court's aggravating findings read as a warning to well-governed firms specifically: the attorneys "benefitted from repeated warnings, internal controls, and firm policies about the dangers of AI misuse," had "regular access to gold-standard legal research databases," and "must have known they would be deeply embarrassed." The court's conclusion: "And yet here we are" [[1]](#ref-1).
This article is written from the perspective of a verification vendor, not a law firm, and it is informational rather than legal advice. Johnson v. Dunn is a single district court decision and binds no other court. Every quotation below is drawn from the published opinion. Confirm how your own jurisdiction handles these questions with counsel.

## What the court actually ordered
Seven items, and only one resembles a conventional sanction. Public reprimand, publication in the Federal Supplement, disqualification from the case, a list of every jurisdiction where the attorneys are licensed, referral to the Alabama State Bar and other licensing authorities, and service of the order on clients, opposing counsel and judges in every pending case. No monetary fine [[1]](#ref-1).
The remedies are worth listing in full, because the shape of them is the point. The court publicly reprimanded three attorneys, Matthew B. Reeves, William J. Cranford, and William R. Lunsford, for the misconduct described in the order [[1]](#ref-1). The sanctions order is also available in accessible form through contemporaneous coverage for readers who would rather not work from the reporter PDF [[4]](#ref-4).
To effectuate that reprimand, it ordered them to provide a copy of the order to their clients, opposing counsel, and the presiding judge in every pending state or federal case in which they were counsel of record, and to every attorney in their law firm, within ten days, certifying compliance within twenty-four hours of completing it [[1]](#ref-1).
It directed the Clerk to submit the order for publication in the Federal Supplement, disqualified all three from further participation in the case, required them to provide a listing of every jurisdiction in which they are licensed within twenty-four hours, and directed the Clerk to serve the order on the General Counsel of the Alabama State Bar and any other applicable licensing authorities [[1]](#ref-1).
The seventh item matters as much as the other six: two other attorneys and the firm itself were released without sanction [[1]](#ref-1). This was not a decision to punish an organisation. The court located responsibility with specific individuals and said so.
Notice what is absent. There is no fine. Our analysis of [what happens when you file a brief with a fake AI citation](https://rankshieldlegal.com/blog/fake-ai-citation-sanctions) covers the monetary end of the range, and the figures there are mostly modest. Johnson v. Dunn suggests the monetary figure was never the real exposure.
Ordered Reach
Public reprimand Three named attorneys [1]
Copy of the order to clients, opposing counsel and the presiding judge Every pending state or federal case where they are counsel of record [1]
Copy of the order to every attorney in the firm Firm-wide, within ten days [1]
Publication in the Federal Supplement Permanent public record [1]
Disqualification From further participation in this case [1]
Referral to licensing authorities Alabama State Bar and any other applicable authority [1]
Released without sanction Two other attorneys and the firm [1]

## Why Rule 11 did not apply
Rule 11(d) provides that Rule 11 "does not apply to... motions under Rules 26 through 37." The filings here were a motion for leave to depose and a motion to compel, both discovery motions under Rules 30 and 37. The court held Rule 11 therefore did not reach them, whatever their content [[1]](#ref-1) [[2]](#ref-2).
This is the part most summaries of the case omit, and it is the part with the widest application. Rule 11 is the certification most lawyers have in mind when they think about their exposure for what a filing says. It is not a general warranty of every paper filed in a case.
The exception is textual and specific. Rule 11(d) states that the rule does not apply to disclosures and discovery requests, responses, objections, and motions under Rules 26 through 37 [[2]](#ref-2). The 1993 advisory committee note explains the reasoning: Rules 26(g) and 37 establish their own certification standards and sanctions, and it is appropriate that those rules, "specially designed for the discovery process," govern such documents rather than the more general provisions of Rule 11 [[1]](#ref-1).
The court then identified the problem with that division of labour. The committee expected Rules 26 and 37 to allow courts to address sanctionable misconduct in discovery motions, but those rules "furnish no basis for the court to address the false statements of law these attorneys made in discovery motions" [[1]](#ref-1) [[3]](#ref-3). Rules 26 and 37 are built around discovery conduct, not around fabricated legal authority.
The court named the result plainly. "This appears to be an unintended anomaly in Rule 11," it wrote, and then: "Regardless, Rule 11 says what it says, it does not apply here" [[1]](#ref-1).
The practical consequence is a gap in the mental model most litigators carry. A fabricated citation in a summary judgment brief runs into Rule 11. The same fabricated citation in a motion to compel does not. Nothing about the conduct changed; only the procedural posture did. Our guide to [responding when opposing counsel files fabricated citations](https://rankshieldlegal.com/blog/opposing-counsel-fabricated-ai-citations) works through the Rule 11 route, and this case is the reminder that the route is not always open.
Rule 11(d) is a federal rule. State procedural rules differ, and some have no equivalent exception. This section describes what the Johnson v. Dunn court held about the federal rule in the case before it; confirm the position in your own jurisdiction.

Source: Johnson v. Dunn, 792 F.Supp.3d 1241 (N.D. Ala. July 23, 2025) Download SVG

## Inherent authority: what fills the gap, and what constrains it
With Rule 11 unavailable, the court proceeded under its inherent power. Quoting Chambers v. NASCO, it noted that while Rule 11 "reaches only certain individuals or conduct, the inherent power extends to a full range of litigation abuses," but that inherent powers "must be exercised with restraint and discretion" and require a finding of bad faith [[1]](#ref-1).
Inherent authority is the residual power a court holds to manage proceedings before it. It is broader than any particular rule and, precisely because it is broader, hedged with more caution.
The opinion sets out the sequence a court is meant to follow. Where bad-faith conduct could be adequately sanctioned under the Rules, a court ordinarily should rely on the Rules rather than the inherent power. But "if in the informed discretion of the court, neither the statute nor the Rules are up to the task, the court may safely rely on its inherent power" [[1]](#ref-1). Having found Rule 11 inapplicable and Rules 26 and 37 unable to reach false statements of law, the court concluded the Rules were not up to the task.
The trade-off is the standard of proof. Rule 11 imposes an objective standard of reasonable inquiry and does not require a finding of bad faith. Inherent-power sanctions do. That is a meaningfully higher bar, and it is the reason the court's findings dwell at length on each attorney's state of mind rather than simply on the fact of the fabrication.
For a firm, the asymmetry cuts in an unexpected direction. The route with the lower threshold, Rule 11, carries the safe harbour and a deterrence-capped remedy. The route with the higher threshold, inherent authority, has no safe harbour and a remedy limited only by what the court considers necessary to vindicate its authority. A lawyer who reasons that discovery motions carry less exposure because Rule 11 does not apply has the analysis backwards.

## The AI policy did not save them, and the court said why
The court's aggravating findings are directed at exactly the firm profile this site usually addresses. The attorneys "benefitted from repeated warnings, internal controls, and firm policies about the dangers of AI misuse" and had "regular access to gold-standard legal research databases." That context made the lapse worse, not better [[1]](#ref-1).
It would be comfortable to read AI-sanctions cases as stories about under-resourced practitioners without governance. This one is the opposite, and it is worth sitting with rather than filing away.
The court described three well-trained, experienced attorneys at "a large, high-functioning, well-regarded law firm," who "benefitted from repeated warnings, internal controls, and firm policies about the dangers of AI misuse," who had "regular access to gold-standard legal research databases," and who "must have known they would be deeply embarrassed in this kind of situation." Its summary was four words: "And yet here we are" [[1]](#ref-1).
Then the sentence that should be read by anyone who has just finished writing an AI policy: "The reality that this lapse in judgment presented in the most spectacularly unforced fashion underscores the need for more than a fine and reprimand" [[1]](#ref-1). The existence of the policy did not mitigate. It raised what the court expected, and the gap between the expectation and the conduct is what drove the remedy past a fine.
This complicates advice this site has given, including in our own guide to building [a defensible law firm AI policy](https://rankshieldlegal.com/blog/law-firm-ai-policy). A policy remains worth having, and firms without one are worse off. But a policy is not a liability shield, and on this court's reasoning it can function as the opposite: evidence of what the lawyer had already been told.
The distinction that survives is between a policy that informs and a control that binds. Repeated warnings are information; the lawyers here had them. What was missing was anything in the workflow that made an unverified citation hard to file. That is the difference between telling people to verify and building a step they cannot skip, which is the argument for making verification a recorded byproduct of the work rather than an instruction people carry in their heads.
And yet the court's summary of three well-trained attorneys, at a well-regarded firm, with AI policies, warnings, internal controls and premium research databases [1]

## "Recklessness tantamount to bad faith"
Because inherent-power sanctions require bad faith, the court had to locate it. It found that an attorney who drafted, signed and filed motions containing another attorney's fabricated citations acted with "recklessness tantamount to bad faith" in failing to ensure the statements were true, and that a second attorney whose name appeared in the signature block acted with "utter disregard" for their truth [[1]](#ref-1).
The standard matters because it explains how a court reaches bad faith without finding that anyone intended to deceive. Nobody in this case is described as having set out to mislead the court.
The findings distinguish between roles in a way that should worry supervising lawyers. One attorney inserted the false citations. Another drafted, signed and personally filed motions containing them. A third had his name in the signature block. Each was found to have acted with recklessness tantamount to bad faith, on distinct facts [[1]](#ref-1).
The signature-block finding is the one with the widest reach. An attorney whose name appears on a filing he did not draft, containing citations he did not insert, was found to have acted with "utter disregard for [the] truth" of the motions [[1]](#ref-1). Being the second name on a filing is not a passive status.
That is the same principle the Ninth Circuit reached from a different direction in [its point-of-signing decision](https://rankshieldlegal.com/blog/ninth-circuit-ai-sanctions-precedent). Two courts, two procedural vehicles, one conclusion: the signature is where responsibility attaches, and it does not distribute across the people who touched the document.

## The consequence class nobody plans for
The requirement to serve the order on clients, opposing counsel and the presiding judge in every pending case, plus every attorney in the firm, is a remedy with no fixed size. Its magnitude depends on how busy the lawyer is. A monetary sanction is bounded at the moment it is imposed; this is not [[1]](#ref-1).
Firms model sanctions exposure as a number. This remedy has no number. Its weight scales with the sanctioned lawyer's active caseload, and for a partner at a large firm that is a great many separate disclosures to clients who had no involvement in the matter.
Consider the mechanics. Every current client receives a court order describing their lawyer's misconduct. Every opposing counsel in every active matter receives the same document, along with whatever tactical use they choose to make of it. Every presiding judge receives it, which means it enters the working knowledge of the bench in front of which that lawyer appears. And every attorney at the firm receives it internally [[1]](#ref-1).
The compliance window compresses it further: ten days to complete, with certification to the court within twenty-four hours of completing [[1]](#ref-1). There is no version of that timeline that allows the disclosure to be managed quietly.
Publication in the Federal Supplement makes it permanent [[1]](#ref-1). A monetary sanction is paid and concluded. A published opinion naming three attorneys, quoting their fabricated citations, and describing their firm's policies as having been in place and ignored is a document that will be found by anyone who looks, indefinitely.
The honest planning consequence is that the reputational and relationship exposure is the exposure. Any risk model that treats AI-citation failures as a bounded financial risk is modelling the wrong variable.

## Disqualification, and why the court found no hardship
Disqualification usually fails because it punishes the client rather than the lawyer. The court addressed that directly, acknowledging that disqualification "often work[s] substantial hardship on the client," but finding no hardship here because the Attorney General's office had a ready team of capable attorneys, some already on the matter [[1]](#ref-1).
The reason disqualification is rare as a sanction is that its cost falls mainly on someone who did nothing wrong. Courts are reluctant to deprive a party of chosen counsel because of counsel's misconduct.
The court ran that analysis and found it did not bite. At the show cause hearing, the representative of the Alabama Attorney General did not suggest any hardship for the defendant, and the court noted that the Attorney General's office had a ready team of capable attorneys who could step in, some of whom already represented other parties [[1]](#ref-1).
That reasoning contains a conditional worth noticing. Disqualification became available because the client could absorb it. A solo practitioner's client, or a client whose matter depends on one lawyer's accumulated knowledge, presents a different calculation, and the same misconduct might produce a different remedy for reasons that have nothing to do with the lawyer's culpability.
It also means the remedy is least available exactly where the client is most dependent, which is not a comforting symmetry but is the operative one.

## What actually mitigated
The court considered and rejected suspension from practice in the district. What persuaded it were things done after the discovery: the firm's internal review, an independent investigation by outside counsel, sincere remorse, and one attorney's commitment to educating others. Response, not policy, is what moved the outcome [[1]](#ref-1).
Having found the pre-existing governance aggravating, the court found the post-discovery response mitigating, and the contrast is the most transferable lesson in the opinion.
It identified two investigative facts specifically: the firm's internal review, and an independent investigation by outside counsel, which together "reassure the court that suspension from the practice of law in the Northern District is not necessary to protect other courts or cases" [[1]](#ref-1). The firm reviewed its Alabama federal filings and Eleventh Circuit appeals and engaged independent counsel to audit for other erroneous citations.
The court also noted that the lawyers were "sincerely apologetic and remorseful," and that one was "committed to educating others about these matters as a preventive measure" [[1]](#ref-1). Those are not procedural moves; they are conduct the court evidently found credible.
Read alongside the aggravating findings, the pattern is clear enough to plan around. What a firm had in place before the incident did not help. What it did after the incident kept three lawyers practising in the district. That should shape how a firm designs its response plan, and it is a different emphasis from what most AI-governance advice puts first. Our guide on [the AI incident response plan](https://rankshieldlegal.com/blog/law-firm-ai-incident-response-plan) covers the mechanics; this case is the argument for having one.
The independent audit is the specific element worth copying. A firm investigating itself and reporting that it found nothing is a weaker signal than an outside firm doing the same work, and the court's language suggests it treated the two as distinct sources of reassurance.

## What to take from this
Four things: Rule 11 does not cover discovery motions and inherent authority is harsher where it applies; a policy raises the standard you are held to rather than shielding you; the signature block is not a passive role; and the response after discovery carries more weight than the governance before it.
None of this depends on Johnson v. Dunn being binding, and it is not binding anywhere. It depends on the reasoning being available to any court facing similar facts, which it plainly is.
The first point is scope. A firm that has trained its lawyers to think about Rule 11 has trained them for one category of filing. Discovery motions sit outside it, and the authority that reaches them is less predictable and less bounded [[1]](#ref-1) [[2]](#ref-2).
The second is about what policies do. They inform, and informed conduct that falls short is judged against what the lawyer was told. If the firm's AI governance consists of warnings and a written policy, it has built something that raises expectations without constraining behaviour.
The third is that verification has to be structural rather than exhortative. The distance between "we told everyone to verify citations" and "an unverified citation cannot reach a filing without a recorded check" is the distance between this case and a firm that never generates it. That is the argument for verification that produces its own record as a byproduct, which our guide on [proving verification to a court](https://rankshieldlegal.com/blog/prove-you-verified-ai-citations-to-court) works through.
The fourth is that the remedy set is wider than money. Disqualification, cascading disclosure to every client and judge, referral to every licensing authority, and permanent publication are all available, and none of them appears in a risk model built around fine amounts.

Test yourself
## Test yourself on the Rule 11 gap
Five questions on what happens when the rule everyone relies on does not apply.

- 1 Why did Rule 11 not apply in Johnson v. Dunn? The attorneys withdrew the filings in time Rule 11(d) excepts motions under Rules 26 through 37, and these were discovery motions The court lacked jurisdiction **Answer:** Rule 11(d) excepts motions under Rules 26 through 37, and these were discovery motions The filings were a motion for leave to depose and a motion to compel. The court held Rule 11 did not reach them by operation of Rule 11(d), calling the result "an unintended anomaly" because Rules 26 and 37 furnish no basis to address false statements of law.
- 2 Does Rule 11 being unavailable mean lower exposure? Yes, fewer rules apply No, inherent authority has no safe harbour and no deterrence cap It makes no practical difference **Answer:** No, inherent authority has no safe harbour and no deterrence cap Inherent power requires a bad-faith finding, a higher bar for the court, but carries neither Rule 11's safe harbour nor its limit to what suffices to deter. Here it produced disqualification, bar referral, cascading disclosure and publication, with no fine.
- 3 How did the court treat the firm's existing AI policies? As mitigating, showing good faith As aggravating, because the lawyers had already been warned It did not consider them **Answer:** As aggravating, because the lawyers had already been warned The court noted the attorneys "benefitted from repeated warnings, internal controls, and firm policies about the dangers of AI misuse" and had premium research databases, then concluded "And yet here we are," finding the unforced nature of the lapse underscored the need for more than a fine.
- 4 What did the court order regarding other cases? Nothing beyond this matter Service of the order on clients, opposing counsel and judges in every pending case A stay of all the attorneys' active matters **Answer:** Service of the order on clients, opposing counsel and judges in every pending case Within ten days, with certification within twenty-four hours of compliance, and additionally to every attorney in their firm. It is a remedy with no fixed size: its weight scales with how busy the sanctioned lawyer is.
- 5 What did the court identify as mitigating? The firm's pre-existing AI policy The internal review and an independent outside investigation after discovery The absence of prior discipline **Answer:** The internal review and an independent outside investigation after discovery Those two investigative steps together reassured the court that suspension was not necessary to protect other courts or cases. What the firm did after the incident mattered; what it had in place beforehand did not help.
Honest self-check. There is no sign-up, and nothing is stored.

Questions answered
## Straight answers to the common questions
The questions readers ask about this topic, answered directly. **No forms, no sales pitch.**

JAMIE KLONCZ · SEO AGENCY NAPLES ************** ONLINE
Pick a question on the left, or search above. You will get the direct answer, the way an answer engine would give it.

← PREV NEXT → [REQUEST ACCESS →](https://rankshieldlegal.com/contact/)

- **Does Rule 11 apply to fabricated citations in discovery motions?** Not in federal court, on the reasoning of Johnson v. Dunn. Rule 11(d) provides that Rule 11 does not apply to disclosures and discovery requests, responses, objections, and motions under Rules 26 through 37. The filings at issue were a motion for leave to depose and a motion to compel, both discovery motions, so the court held Rule 11 did not reach them regardless of what they contained. The court called this "an unintended anomaly in Rule 11," explaining that the 1993 advisory committee expected Rules 26 and 37 to address such misconduct, but that those rules "furnish no basis for the court to address the false statements of law these attorneys made in discovery motions." Its conclusion was blunt: "Rule 11 says what it says, it does not apply here." State procedural rules differ and some have no equivalent exception, so confirm the position in your own jurisdiction.
- **If Rule 11 does not apply, does that mean less exposure?** No, and assuming so gets the analysis backwards. With Rule 11 unavailable the court proceeded under its inherent authority, which the opinion describes as extending to "a full range of litigation abuses" while Rule 11 "reaches only certain individuals or conduct." The trade-off is the standard: Rule 11 applies an objective reasonable-inquiry test and requires no finding of bad faith, while inherent-power sanctions do require bad faith, which is a higher bar for the court to clear. But Rule 11 also carries a safe harbour and a remedy capped at what suffices to deter. Inherent authority carries neither. In Johnson v. Dunn the result was public reprimand, disqualification, bar referral, cascading disclosure across every pending case, and publication, with no monetary fine at all. The less predictable route produced the harsher outcome.
- **Did having an AI policy help the lawyers in Johnson v. Dunn?** The opposite. The court's aggravating findings noted that the attorneys "benefitted from repeated warnings, internal controls, and firm policies about the dangers of AI misuse," had "regular access to gold-standard legal research databases," and "must have known they would be deeply embarrassed in this kind of situation," before concluding: "And yet here we are." It then found that the lapse having occurred "in the most spectacularly unforced fashion underscores the need for more than a fine and reprimand." The policy did not mitigate; it established what the lawyers had already been told and made the shortfall starker. The distinction that matters is between a policy that informs and a control that binds. A firm whose AI governance consists of warnings has raised the standard it will be judged against without changing what is possible to file.
- **What sanctions did the court actually impose?** Seven ordered items, and none was a fine. The court publicly reprimanded three named attorneys; ordered them to provide a copy of the order to their clients, opposing counsel and the presiding judge in every pending state or federal case in which they were counsel of record, and to every attorney in their firm, within ten days with certification within twenty-four hours of compliance; directed the Clerk to submit the order for publication in the Federal Supplement; disqualified all three from further participation in the case; required them to list every jurisdiction in which they are licensed within twenty-four hours; and directed the Clerk to serve the order on the General Counsel of the Alabama State Bar and any other applicable licensing authorities. It released two other attorneys and the law firm itself without sanction, locating responsibility with named individuals rather than the organisation.
- **Is a lawyer whose name is only in the signature block responsible?** On this court's findings, yes. Because inherent-power sanctions require bad faith, the court had to make individualised findings, and it made distinct ones for each attorney. An attorney who drafted, signed and personally filed motions into which another attorney had inserted false citations was found to have acted with "recklessness tantamount to bad faith" in failing to ensure the statements were true. A further attorney whose name appeared in the signature block was found to have acted with "utter disregard" for the truth of motions bearing his name. Being the second name on a filing was not treated as a passive status. That aligns with the Ninth Circuit's separate conclusion that responsibility attaches at the point of signing, reached through a different procedural vehicle in a different circuit.
- **What mitigated the sanction?** What the firm and lawyers did after the problem surfaced, not what was in place beforehand. The court expressly considered suspension from practice in the Northern District and rejected it, citing the firm's internal review and an independent investigation by outside counsel as together reassuring it that suspension "is not necessary to protect other courts or cases." It also noted that the lawyers were sincerely apologetic and remorseful and that one was committed to educating others as a preventive measure. The firm reviewed its Alabama federal filings and Eleventh Circuit appeals and engaged independent counsel to audit for other erroneous citations. The independent element appears to have carried weight of its own: a firm investigating itself and reporting a clean result is a weaker signal than an outside firm reaching the same conclusion.
- **Why did the court disqualify the attorneys when that usually harms the client?** Because on these facts it found no hardship to the client. The court acknowledged directly that disqualification "often work[s] substantial hardship on the client," which is the usual reason courts avoid it as a sanction. It then found the concern did not apply: at the show cause hearing the representative of the Alabama Attorney General did not suggest any hardship for the defendant, and the Attorney General's office had a ready team of capable attorneys who could step in, some of whom already represented other parties in the matter. That reasoning carries a conditional worth noting. Disqualification became available because this particular client could absorb it. A client dependent on a single lawyer's accumulated knowledge presents a different calculation, so identical misconduct could draw a different remedy for reasons unconnected to the lawyer's culpability.

## References

- U.S. District Court for the Northern District of Alabama, Southern Division. Johnson v. Dunn, 792 F.Supp.3d 1241, No. 2:21-cv-1701-AMM (signed July 23, 2025). July 2025. [https://www.law.berkeley.edu/wp-content/uploads/archive/2025/12/Johnson-v-Dunn.pdf](https://www.law.berkeley.edu/wp-content/uploads/archive/2025/12/Johnson-v-Dunn.pdf)
- Legal Information Institute, Cornell Law School. Federal Rule of Civil Procedure 11, including Rule 11(d) inapplicability to discovery motions. 2026. [https://www.law.cornell.edu/rules/frcp/rule_11](https://www.law.cornell.edu/rules/frcp/rule_11)
- Legal Information Institute, Cornell Law School. Federal Rule of Civil Procedure 37: Failure to Make Disclosures or to Cooperate in Discovery, Sanctions. 2026. [https://www.law.cornell.edu/rules/frcp/rule_37](https://www.law.cornell.edu/rules/frcp/rule_37)
- Courthouse News Service. Johnson v. Dunn: attorney sanctions order. 2025. [https://www.courthousenews.com/johnson-vs-dunn-attorney-sanctions-order/](https://www.courthousenews.com/johnson-vs-dunn-attorney-sanctions-order/)

Written by
## [Jamie Kloncz](https://rankshieldlegal.com/about/)
Founder, RankShield
Jamie Kloncz is the founder of RankShield, the verifiable AI and quantum security platform behind RankShield Legal. An engineer by training, he built RankShield after his own devices and business were attacked, including an AI voice-cloning scam that targeted his family, on one conviction: unverifiable security is the real danger, so every consequential action should leave a receipt anyone can independently check.
[More about Jamie →](https://rankshieldlegal.com/about/)

Try it · Free
## Check a citation against live case-law
Paste a citation from an AI-drafted brief and see whether the case actually exists, resolved against live case-law. Free, no sign-up. Then request early access to certify a full filing.
[Try the citation checker](https://rankshieldlegal.com/ai-legal-citation-checker/)

Keep reading
## Related guides
[Litigation & Evidence The First Federal Appeals Court AI Sanctions Precedent: What "Responsibility at the Point of Signing" Means Read guide →](https://rankshieldlegal.com/blog/ninth-circuit-ai-sanctions-precedent/)[Litigation & Evidence Opposing Counsel Filed Fabricated AI Citations: How to Respond Without Losing Your Motion Read guide →](https://rankshieldlegal.com/blog/opposing-counsel-fabricated-ai-citations/)[Legal AI Building a Defensible Law Firm AI Policy Read guide →](https://rankshieldlegal.com/blog/law-firm-ai-policy/)