Tyrone Blackburn is now under judicial scrutiny after a federal judge flagged a suspicious legal citation in a lawsuit tied to Diddy, raising questions about the use of generative AI in court filings and prompting a mandatory in-person appearance next month.
Judge Leo M. Gordon issued the order after Blackburn submitted an opposition brief in the case involving Diddy accuser Liza Gardner, referencing a case titled United States v. Masha, 99 F.3d 1005 (7th Cir. 2021).
But when Diddy’s attorney Erica Wolff attempted to verify the citation, she told the court it was nowhere to be found.
“We found a matter involving someone named Masha,” Wolff said during a November 17 hearing, “but it does not have that citation, is not in that reporter, is not in the Seventh Circuit, and has absolutely nothing to do with the issues in this case.”
When pressed by Judge Gordon, Blackburn admitted to using generative AI to assist with legal research but insisted he wrote the filing himself.
“Yeah, see, I don’t have all of, I’ve pulled over 200 cases from my, so I will get that. When I go back to my home, I will provide the court with that,” Blackburn told the judge.
The court gave him a deadline to either produce the cited case or notify both the court and opposing counsel that he could not do so. That deadline came and went without a response. Wolff later informed the court that Blackburn also failed to respond to attempts to discuss the issue.
Judge Gordon noted that this was not the first lapse in communication from Blackburn in the Gardner case and cited court rules requiring accuracy and diligence in all filings.
“Mr. Blackburn was included on the email to this Court and has not acknowledged receipt or responded. Despite having every opportunity to do so…Mr. Blackburn has not complied with the court’s directive,” Judge Gordon wrote.
The judge’s order now requires Blackburn to explain why parts of his filing should not be thrown out and why he shouldn’t face penalties for the citation error. The citation issue adds to the ongoing legal battle involving Gardner, who claims that Diddy and singer Aaron Hall assaulted her when she was 16 following an MCA Records event in New York.
According to her lawsuit, she and a friend were taken to Hall’s apartment, given alcohol and coerced into sexual acts. Gardner also alleges Diddy returned days later and physically assaulted her, fearing her friend might talk.
Gardner is seeking to move the case to New Jersey, arguing that significant parts of the alleged misconduct occurred there. Diddy has denied all allegations. Blackburn’s involvement in the Gardner case follows two other high-profile legal disputes where courts questioned his use of AI-generated case law.
In a defamation suit brought by Fat Joe, Blackburn filed a motion to dismiss that included several citations opposing counsel said didn’t exist.
After being called out, Blackburn asked the court for permission to revise the brief to fix the errors. The judge denied the request and criticized the lack of care taken in the original filing.
In another case involving TD Jakes, Blackburn was accused of submitting documents with “bogus” citations that forced the opposing legal team to spend time and money verifying false information.
Jakes’ legal team requested over $70,000 in fees due to the extra work. A judge later sanctioned Blackburn, concluding the filings relied on non-existent case law likely generated by AI and not adequately vetted.
Blackburn is scheduled to appear in person in Newark, New Jersey, on December 3 to respond to Judge Gordon’s concerns.
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