Law360 (February 9, 2026, 3:07 PM EST) -- A Connecticut labor litigator's vow to permanently cease using generative artificial intelligence tools in his practice after he allowed AI-generated errors to appear in separate but similar June filings has weighed in his favor as a Bridgeport federal judge ordered sanctions against the attorney.

In his Friday order, U.S. District Judge Stefan R. Underhill said solo practitioner David Stitch must complete three hours of continuing legal education courses on responsible AI use and must publicly share what he learned with the local legal community, through a channel such as an op-ed or blog post.

Judge Underhill did not impose financial sanctions on Stitch, nor did he sanction the lawyer's co-counsel and daughter, Stephanie Stitch, whom he found "may not have been entirely candid" regarding the matter, but who did not have a hand in the AI misuse.

The younger Stitch requested to file a "corrected version" of the erroneous brief but did not notify the court of the AI hallucinations contained in the original, Judge Underhill said. Stephanie Stitch later "apologized for her conduct and indicated that she was currently enrolled in continuing legal education programs on the responsible use of AI in legal practice."

The AI-generated false citations were contained in an opposition brief Stitch filed on behalf of client Raul Gonzales Davila in June, amid Gonzales Davila's Fair Labor Standards Act suit against Roblen LLC, which formerly did business as Vicolo Pizza Restaurant, and Viktor Berisha.

On Feb. 2, Berisha filed a notice of pro se appearance, notifying the court that he would begin representing himself in the matter because he could no longer afford to retain outside representation.

In November, U.S. District Judge Janet C. Hall sanctioned the elder Stitch $500 in a separate but related case also pending before the U.S. District Court for the District of Connecticut, in which Stitch represented a different former Vicolo employee. Those errors were likewise contained in an opposition brief filed on the same day.

In that instance, Judge Hall noted Stitch's "sincere and unreserved apology" upon discovering his own citation errors, which weighed in his favor. In a similar vein, Judge Underhill last week made note of Stitch's "accountability for his errors" as well as his pledge to avoid future use of the technology.

Stitch and Berisha did not immediately respond to comment requests Monday.

Raul Gonzales Davila is represented by David Stitch and Stephanie L. Stitch of Stitch Law and Richard Rapice of the Law Office of Richard J. Rapice LLC.

Berisha and Roblen represent themselves pro se.

The case is Davila v. Roblen LLC et al., case number 3:23-cv-00512, in the U.S. District Court for the District of Connecticut.

--Editing by Rich Mills.

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