A former credit union employee can move forward with workplace sex discrimination claims in federal court, while her attorney must respond to threatened sanctions for using incorrect, potentially AI-generated case citations.
Don Quinn, a plaintiffs’ attorney at Quinn Patton in Washington, D.C., filed a brief with at least three citations to prior federal court opinions that referenced language or findings not appearing in those opinions, according to a Tuesday decision from the US District Court for the District of Columbia.
Judge Loren L. Alikhan ordered Quinn to explain within 14 days the reason for those errors and whether he used generative artificial intelligence in writing the brief.
Courts across the US have been grappling with attorneys’ increasing use of generative AI, in some instances issuing fines for fake case citations or restricting the technology’s use. Just in the past two months, federal courts have warned or sanctioned attorneys in bias , bankruptcy and Justice Department cases. California is close to becoming the first state to pass legislation setting guardrails on AI’s use in legal practice, if the governor signs the bill waiting on his desk.
Meanwhile his client, Wanda Garner, largely defeated her former employer’s motion to dismiss her bias claims under federal and D.C. law. The court sided with the employer, Transit Employees Federal Credit Union, only in dismissing Garner’s claim under D.C.’s Family and Medical Leave Act.
The credit union indefinitely suspended Garner purportedly for performance and attendance problems in 2025, after she took time off work to deal with her child’s health-related emergencies. Garner said at least one coworker with attendance problems wasn’t similarly disciplined. The employer also denied Garner’s two requests for leave, one for mental health reasons related to work stress and another to attend the memorial service of a deceased family member, according to the decision.
She claimed sex-based discrimination and retaliation under Title VII of the 1964 Civil Rights Act, as well as bias based on family responsibilities under D.C.’s Human Rights Act.
The credit union had moved for summary judgment, or in the alternative to dismiss Garner’s claims, because she couldn’t show the job performance problems cited in her suspension were pretext for discrimination. The court found it was premature to rule on a motion for summary judgment, because Garner showed she needs to pursue discovery to gather facts that might help prove her case.
John M. Bredehoft of Kaufman & Canoles P.C. represents the credit union.
Bredehoft declined to comment. Quinn didn’t immediately respond to a request for comment.
The case is Garner v. Transit Employees Federal Credit Union, D.D.C., No. 1:25-cv-04024, 9/22/26.