Judge slams ‘ethical violation of the highest order’
The efforts of former pastor-turned-registered sex offender Duane Youngblood in fending off a defamation lawsuit from megachurch founder T.D. Jakes in Pennsylvania has suffered a massive blow as the attorney who was defending him faces possible sanctions for submitting fabricated quotations and misleading analysis of case law.
In an eight-page memorandum order filed in the U.S. District Court for the Western District of Pennsylvania Thursday, U.S. District Judge William S. Stickman cited significant fabrications and misrepresentations of caselaw by New York City attorney Tyrone Blackburn, whose client claims that Jakes sexually assaulted him when he was a teenager some 40 years ago. Jakes has denied those allegations.
“While reviewing Blackburn’s briefs, the Court became aware of the fact that they contain wholly fabricated quotations from caselaw — including fabricated quotations from the Court’s own prior opinion. … In addition to including non-existent quotations, the briefs repeatedly misrepresent case law,” Stickman wrote a day after Blackburn asked the court to withdraw as Youngblood’s attorney.
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Blackburn did not respond to a request for comment from The Christian Post.
“Jakes also noticed the issues with Youngblood’s brief and addressed them in his brief opposing Youngblood’s motion to dismiss. In his reply, Blackburn failed to offer any explanation for the deficiencies and fabrications in his brief. Instead, he brazenly attempted to mount a tu quoque defense, asserting that ‘a LexisNexis Document Analysis of Plaintiff’s own opposition briefs reveals a pattern of misquotation, superficial citation, and invocation of authorities that are either inapposite or do not support the propositions for which they are cited.'”
Stickman contended that despite the claims made by Blackburn in his briefs, the court found no fabrications in Jakes’ brief.
“The Court thoroughly reviewed Jakes’ response brief … and did not find any fabricated quotations or misrepresented case law. Only Youngblood, through attorney Blackburn, submitted a brief replete with non-existent quotations and repeated misrepresentations of actual case law,” Stickman stated. “Even more outrageously, a review of Youngblood’s reply brief demonstrates that it too includes fabricated quotes and misrepresents case law. In other words, when accused of a serious ethical violation, attorney Blackburn chose to double down. This is very troubling. The Court views Blackburn’s conduct as a clear ethical violation of the highest order.”
Jakes, 67, founded The Potter’s House in Dallas, Texas, nearly 30 years ago and now serves as chairman of the T.D. Jakes Foundation. He initially filed the defamation lawsuit against Youngblood, 58, last November, a day after suffering a heart attack while preaching. The lawsuit stems from a claim Youngblood made in interviews with internet personality Larry Reid on his “Larry Reid Live” show on Oct. 28 and Nov. 3, 2024, that Jakes assaulted him when he was about 18 or 19 years old. Jakes claims Youngblood engaged in “libel per se” and a civil conspiracy to commit defamatory acts.
In court filings last month, Jakes’ high-profile attorney, Dustin Pusch, argued that Youngblood’s motion to dismiss his lawsuit pursuant to Federal Rules of Civil Procedure Rule 12(b)(6), which allows a defendant to move to dismiss a complaint if it doesn’t allege enough facts to support a plausible legal claim, should be denied for “many reasons,” including what he calls “counterfeit caselaw.”
In a flurry of court filings, Blackburn later redirected the allegations Jakes’ attorneys made against him of fabricating or misquoting case law.
Jakes’ attorneys rejected Blackburn’s claim that they made similar mistakes as “false.” They argued that the errors he picked up in using the LexisNexis AI tool were mostly from quotations of his filing and Stickman agreed in his order.
“The fact that Blackburn submitted fabricated quotations and misleading analysis of case law is plain to see from the face of the briefs. When reviewing Blackburn’s briefs, the Court was perplexed to see quotes attributed to the Courts own prior opinion in this case, as well as other case law, that was wholly fabricated. The Court was also troubled to find that Blackburn repeatedly misrepresented case law to support his contentions,” Stickman wrote.
The Pennsylvania judge explained that while attorneys are allowed to “make creative case comparisons and may even stretch existing case law to support their arguments,” those comparisons must be done within the confines of Federal Rule of Civil Procedure 11(b) and Pennsylvania Rule of Professional Conduct 3.3.
“Attorneys may not fabricate nonexistent quotations, from case law or the Court’s opinion, and may not cite cases for legal propositions for which they do not stand (or even discuss.),” Stickman noted.
He further argued that even if the inaccuracies in Blackburn’s filings were made by “artificial so called ‘intelligence,'” Blackburn is legally and ethically responsible for the work he submits to the court.
“Attorneys have ethical obligations under Rule 11 and their state’s respective professional canons to review every document submitted to a court under their name to ensure accuracy, candor, and overall compliance with ethical obligations. This duty is non-delegable. An attorney who signs and files a brief authored by a non-lawyer, such as a paralegal, secretary, or intern, is personally responsible for all that it contains. The same applies to artificial intelligence,” Stickman wrote.
“In other words, Youngblood [sic] could not outsource his obligations to the court and his client to a third party — including artificial so called ‘intelligence.’ Whoever or whatever drafted the briefs signed and filed by Blackburn, it is clear that he, at the very best, acted with culpable neglect of his professional obligations. The alternative is that he acted in a conscious effort to deceive and mislead the Court,” Stickman argued. “At this point, in light of Blackburn’s continuing offenses in his reply brief, the Court is inclined to believe the latter.”
Stickman ordered that Youngblood’s motion to dismiss Jakes’ lawsuit, according to Rule 12(b)(6), and Reply Memorandum supporting that motion be stricken from the record. He also ordered Youngblood to answer Jakes’ complaint per Federal Rule of Civil Procedure 12 (a)(4)(A) on or before July 11. Blackburn was further ordered to show cause not exceeding 15 pages by July 18 as to why his briefs have not violated Rule 11(b) and Pa. RPC 3.3.
“Specifically, Blackburn is directed to thus show cause as to the fabricated quotations and blatant misrepresentations of case law and the Court’s opinion in his briefs. Possible sanctions include, but are not limited to, monetary sanctions (including attorney’s fees related to the litigation of the motions at issue), revocation of Blackburn’s pro hac vice status, and any other sanctions deemed appropriate by the Court,” Stickman said.
Blackburn is also required to appear in court for a hearing on July 24 at 1:30 p.m. to explain why he should not be sanctioned for potential violations of Rule 11(b).
“If Jakes plans to seek attorneys’ fees in relation to the litigation surrounding the motion to dismiss …, Jakes and his counsel must attend the hearing. Otherwise, all parties and counsel are welcome to attend the show cause hearing, but only Blackburn’s attendance is required,” Stickman added.
“Blackburn’s attempt to withdraw as counsel in this action does not insulate him from the repercussions of his actions. His pending Withdrawal of Appearance … will remain under advisement until the resolution of the show cause hearing.”
Separately, Blackburn was formally charged with assault by the New York City Police Department on Wednesday morning after a 66-year-old messenger said he suffered a minor injury when he tried to serve Blackburn with a complaint related to a civil lawsuit against rapper Fat Joe on the night of May 12.
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