On July 10, 2026, Magistrate Judge Jennifer Willis of the Southern District of New York issued a critical opinion in the case Dixon v. Roc Nation, addressing lawyer Blackburn's conduct in court filings.

Roc Nation filed a motion for sanctions on June 1, 2026, against Defendants Dixon, Blackburn, and T.A., citing issues with Blackburn's submissions. The court had set a briefing schedule requiring opposition filings by June 30, 2026. Blackburn filed the Defendants' opposition on July 1, 2026, which Roc Nation moved to strike, claiming it was "untimely, exceeds this Court's word limit, and contains what appear to be AI-hallucinated citations."

In response on July 7, Blackburn argued that every case cited was real and "each was cited for a proposition it actually holds," denying allegations of AI hallucinations. However, Blackburn acknowledged including language in quotation marks that did not exactly match the cited cases on seventeen occasions, defending this as paraphrasing or compression that accurately conveyed the courts' holdings rather than fabricating law.

Blackburn further accused Roc Nation of "failing the identical citation audit," listing forty citations he claimed were not verbatim in the cases Roc Nation cited. Roc Nation countered, stating it did not use AI in its filings.

Magistrate Judge Willis expressed deep concern over Blackburn's repeated use of inaccurate quotations, his justification of such behavior despite prior sanctions, and his unfounded allegations against Roc Nation. The judge noted a pattern of misrepresentations by Blackburn, referencing a March 24, 2025, ruling by Judge Oetkin describing Blackburn's filings as "replete with inaccurate statements of law, conclusory accusations, and inappropriate ad hominem attacks on opposing counsel." Additionally, Blackburn was sanctioned in December 2025 in the District of New Jersey for citing nonexistent cases created by AI hallucinations and failing to comply with court orders.

The court concluded that Blackburn's continued reliance on fabricated quotations and refusal to accept responsibility constitutes a serious breach of his ethical and professional obligations.

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