JAKES v. YOUNGBLOOD
2:24-cv-01608
| W.D. Pa. | Jun 26, 2025Background
- Plaintiff Thomas Dexter Jakes filed a complaint against Defendant Duane Youngblood in the U.S. District Court for the Western District of Pennsylvania.
- Youngblood, represented by Attorney Tyrone A. Blackburn (admitted pro hac vice from New York), filed a motion to dismiss and supporting briefs.
- The Court discovered that Blackburn's briefs contained fabricated quotations attributed to both case law and the Court’s own prior opinions, as well as misrepresentations of actual case law.
- Jakes pointed out these issues in his opposition; the Court confirmed Jakes’ briefs contained no such fabrications or misrepresentations.
- Blackburn did not provide an explanation for the fabricated quotes, doubling down on his defense in reply.
- The Court struck Youngblood’s briefs from the record, ordered Blackburn to show cause regarding possible violations of Rule 11(b) and Pa. RPC 3.3, and scheduled a show cause hearing to determine appropriate sanctions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fabricated quotations and case law | Defendant’s briefs fabricated quotes, misrepresented law | Plaintiff’s brief also alleged to misquote/misrepresent law | Only defendant’s briefs contained fabrications; strike briefs. |
| Duty of candor to the court | Plaintiff complied with Rule 11 and Pa. RPC 3.3 | Defendant claimed errors were also present in plaintiff’s briefs | Defendant’s attorney violated ethical rules. |
| Use of AI in legal filings | Plaintiff did not raise | Defendant implied errors may be due to AI-generated content | Attorney responsible, regardless of AI use. |
| Sufficiency of complaint | Plaintiff’s complaint not deficient as claimed | Defendant misrepresented court’s prior opinion | Court made no findings as defendant claimed. |
Key Cases Cited
- Eagan by Keith v. Jackson, 855 F. Supp. 765 (E.D. Pa. 1994) (discussing an attorney’s overarching duty of candor to the court)
- Salovaara v. Eckert, 222 F.3d 19 (2d Cir. 2000) (sanctions for abuse of the adversary system under Rule 11)
- Storey v. Cello Holdings, L.L.C., 347 F.3d 370 (2d Cir. 2003) (incorrect legal statements are not sanctionable under Rule 11(b)(2))
- Martin v. Brown, 63 F.3d 1252 (3d Cir. 1995) (procedure for court-initiated Rule 11 sanctions)
- Marcone v. Penthouse Int’l, 754 F.2d 1072 (3d Cir. 1985) (standards for pleading and proving actual malice)