The sanctions record · U.S. District Court, Middle District of Tennessee, 2026
In re BFI Waste Systems of Tennessee
No. 3:22-cv-00605 (M.D. Tenn., Nashville Division) · order of Evans, M.J., 6 August 2026
Page verified 15 August 2026. Quotations are from the court’s own order, linked below.
A public reprimand delivered by the order itself, plus $1,500.00. The reprimand is the larger half of the penalty: it is written into a published order, which means it is permanent and searchable. The money is paid once. The order is read for years.
The record
- CourtUnited States District Court, Middle District of Tennessee, Nashville Division
- JudgeLuke A. Evans, United States Magistrate Judge
- Docket3:22-cv-00605
- Order6 August 2026
- Tool namedNone. The opinion addresses AI powered legal research tools generally.
- RuleFederal Rule of Civil Procedure 11
- Sanction$1,500.00, payable to the Clerk of the Court within 30 days after entry of the order
- AdditionalPublic reprimand
What the court held
“Attorney Ringger has violated Rule 11 and is hereby publicly reprimanded through this order. Ringger also is assessed a monetary sanction of $1,500.00, payable to the Clerk of the Court within 30 days after entry of this order.”
No tool is named. The court treats AI powered legal research tools as a class and applies Rule 11 to the filing regardless of which one produced it.
Why it matters
The phrase “publicly reprimanded through this order” is the operative one. The reprimand is not a separate disciplinary step that might stay private. It is the order, and the order is public. Anyone searching the attorney’s name finds it.
Read with Barteca two days earlier: two federal courts, in the same week, reached the same finding by the same rule, one naming three tools and one naming none. The tool is not the variable.
The lesson for the next filing
Rule 11 does not ask which tool you used. It asks whether you read what you filed. A record of what you checked, made at the moment of filing, is the answer to that question, and it is the answer this order says was missing.
Sources
Related
- The full sanctions record
- Barteca Holdings v. Tacobarn Newtown, two days earlier, three tools named
- Fivehouse v. U.S. Department of Defense, the other reprimand on this record
- Every verified AI standing order
Checked 15 August 2026. Quoted from the court’s own order. Information, not legal advice.
Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.