Combs-Roberson AI Lawsuit: Fake Case, Sanctions, Contempt Hearing

In December 2025, U.S. District Judge Leo M. Gordon sanctioned attorney Tyrone A. Blackburn $6,000 under Federal Rule of Civil Procedure 11 for citing a fabricated, AI-generated case in a brief filed in Gardner v. Combs, a civil sexual assault lawsuit against Sean “Diddy” Combs. Blackburn then missed the first two installment payments, and in May 2026 the judge held him in contempt but declined to impose jail time or additional fines after incoming counsel for the plaintiff agreed to pay the balance.¹

The Fake Case He Cited

Blackburn represented plaintiff Liza Gardner in a suit accusing Combs and R&B singer Aaron Hall of sexually assaulting her in 1990. Universal Music Group was among the corporate defendants named. In a brief opposing UMG’s dismissal, Blackburn repeatedly cited United States v. Masha, 990 F.3d 1005 (7th Cir. 2021), for the proposition that UMG could be held complicit under the Mann Act because it allegedly knew of prior misconduct by Combs and Hall.²

The case did not exist. It was a hallucination produced by generative AI software. After the court issued an order to show cause, Blackburn admitted in a letter that he had “fabricated legal propositions derived from generative artificial intelligence.”³ Judge Gordon’s ruling identified multiple missed chances to catch it: Blackburn did not verify the citation after opposing counsel flagged it as questionable, did not produce a copy of the supposed decision when directed, and did not correct it while preparing for oral argument.⁴

What the Sanctions Order Required

Judge Gordon, a judge on the U.S. Court of International Trade sitting by designation in the District of New Jersey, applied Rule 11’s “reasonableness under the circumstances” standard and found Blackburn negligent. The order notes that Rule 11 does not require a finding of bad faith; negligence alone is enough.⁴

The December 2025 order imposed three obligations on Blackburn:

A $6,000 fine, payable in $500 monthly installments starting in March 2026.
Self-reporting to bar associations in both New Jersey and New York.
Providing his client, Gardner, with copies of the sanctions order, the underlying filings, and the show-cause hearing transcript, and discussing the implications with her.

The court characterized the fabrication as part of a “broader pattern of negligent research practices and missed deadlines in multiple jurisdictions.”¹

The Contempt Hearing

Blackburn missed the March and April 2026 payments and did not tell the court he could not pay.² Judge Gordon ordered him to appear on May 11, 2026, to show cause why he should not be held in contempt. At the hearing, Blackburn said he had sent one payment and produced a certified mail receipt, but the court said no payment had been received.¹

Judge Gordon found Blackburn in contempt but declined to jail him or add fines. He told Blackburn, “Your conduct and behavior is lacking,” and said the hearing was his “last warning.” Attorney Marjorie Mesidor, appearing as incoming counsel for Gardner, said her team would pay the remaining $6,000 to keep the underlying case moving.¹ The claims against Combs and Hall remain pending; UMG was dismissed from the case by Judge Gordon in January 2026.⁵

Not Blackburn’s First Sanction

The Gardner ruling drew on documented prior discipline against Blackburn in several courts:

In Zunzurovski v. Fisher (S.D.N.Y., 2024), Judge Denise Cote referred him to the court’s Grievance Committee, finding he had filed cases without diligently investigating jurisdiction or venue in an effort to “garner media attention, embarrass defendants with salacious allegations, and pressure defendants to settle quickly.”⁶
In Jones v. Combs (S.D.N.Y., 2025), a separate Combs-related case in which Blackburn represented producer Rodney Jones, Judge J. Paul Oetken issued a formal warning over inaccurate statements of law and personal attacks on opposing counsel.⁷
In Jakes v. Youngblood (W.D. Pa., 2025), a federal judge imposed $5,000 in sanctions after Blackburn submitted fabricated cases and misrepresentations in two briefs.⁷
In Facey v. Fisher (N.Y. Sup. Ct., 2025), a state justice ordered him to explain why his motion papers “repeatedly cite to cases that do not exist and/or stand for legal propositions that are discussed nowhere in the cited decisions.”⁷

In a March 2026 proceeding, Cartagena v. Dixon, a federal court noted that it had received a letter from LexisNexis refuting Blackburn’s claim that he had been using the company’s AI legal research platform, undermining his attempt to blame the tool for the fabricated citations. That court issued a public admonition and warned that future misconduct could bring further sanctions or a disciplinary referral.⁷

Where This Fits in the AI Citation Crackdown

Blackburn’s sanction is one of a growing number. A researcher tracking these incidents reported that documented cases of AI-generated fabrications in court filings had climbed from a handful per month to several per day, with over 600 recorded nationwide by late 2025. Punishments have escalated. In Whiting v. City of Athens, a 2026 Sixth Circuit ruling, two Tennessee attorneys were ordered to pay $15,000 each in punitive sanctions on top of attorneys’ fees for submitting briefing with more than 24 fake citations. A California appellate court that fined another attorney $10,000 for 21 fake AI citations stated the standard directly: “No brief, pleading, motion, or any other paper filed in any court should contain any citations that the attorney responsible for submitting the pleading has not personally read and verified.”⁸

1
Law360. Combs Accuser’s Atty Avoids Jail for Overdue AI Fine
2
Bloomberg Law. Attorney in Diddy Case in Trouble for AI Fake Citation Blunder
3
Billboard. Diddy Accuser Lawyer AI Court Filings Judge Punish Him
4
Weiner Law. AI Cite in Court Rule 11
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Law360. Universal Music Cut Loose From Diddy Sex Assault Suit
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Justia. Zunzurovski v. Fisher et al Opinion and Order
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Cartagena v. Dixon. Cartagena v. Dixon Opinion
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The Daily Record. California Lawyer AI Fake Citations Fine