By Mike Scarcella

WASHINGTON, July 13 (Reuters) - A lawyer who was sanctioned twice for allegedly misusing artificial intelligence has been rebuked again by a federal judge in New York who said the attorney included AI-fabricated quotations in a court filing in a lawsuit against entertainment company Roc Nation.

Manhattan-based U.S. Magistrate Judge Jennifer Willis in an order on Friday said attorney Tyrone Blackburn showed a "continued pattern of behavior" involving AI.

The judge said Blackburn's filing, which he submitted to argue against unrelated sanctions sought by Jay-Z's Roc Nation in the case, contained quotations that did not appear in the cases he cited.

"Blackburn's repeated inclusion of fabricated quotes in his filings demonstrates a pattern of complete disregard for his ethical obligations to make accurate representations to the Court," Willis wrote. She called his conduct "an outrageous breach of his ethical and professional obligations."

Blackburn on Monday said he will respond to the court's order but declined further comment.

Roc Nation and a lawyer for the company at Quinn Emanuel did not immediately respond to requests for comment. Blackburn denied relying on fabricated case law.

Blackburn brought the lawsuit on behalf of Terrance Dixon, a performer and collaborator with rap star Fat Joe who alleges the musician and his management company Roc Nation engaged in employment-related misconduct. Dixon claims lost wages and other harms. Roc Nation and Fat Joe have denied the allegations.

Judges across the United States have sanctioned attorneys for submitting AI-assisted filings that contained errors. Professional rules permit lawyers to use AI tools but require them to ensure the accuracy of their filings.

Blackburn was sanctioned by a New Jersey federal court in December for citing nonexistent cases created by AI hallucinations, and a Pennsylvania federal judge last year fined him $5,000 over allegedly fabricated quotations.

In the New York case, Roc Nation asked the court last month to sanction Blackburn for pursuing what it called baseless claims. It then urged the court to strike Blackburn's opposition filing, saying it was filed too late and contained what appeared to be AI-hallucinated citations.

In a July 7 filing, Blackburn countered that each of the court decisions he cited “is a real, published, binding authority," though he said he paraphrased some material.

Willis said Blackburn’s explanation “brazenly minimizes” his conduct.

“When his fabricated quotes were discovered by counsel for Roc Nation in this case, he doubled down and made baseless accusations against opposing counsel,” the judge wrote.

The case is Terrance Dixon v. Joseph Cartagena et al, U.S. District Court, Southern District of New York, No. 1:25-cv-05144-JLR-JW.

For Dixon: Tyrone Blackburn

For Roc Nation: Alex Spiro of Quinn Emanuel

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