Part of: Mace Federal Removal (Berg v. Bryant → D.S.C.) · Berg v. Bryant (and Bryant's Third-Party Complaint against Mace) · Assignment Desk Works, LLC v. Alexis Berg · Musgrave v. Mace (2:25-cv-01823-RMG) · Litigation Overview & Court-Filing Index
Bryant moves for sanctions over 'fake, AI generated citations' in Mace legal brief, and a cover-up that compounded them
Patrick Bryant filed a Rule 11 sanctions motion in the Berg v. Bryant litigation alleging that Rep. Nancy Mace's attorney submitted AI-fabricated case citations in a court brief, then, the motion alleges, attempted to conceal the error by filing an amended brief that itself allegedly continued to use fabricated citations. Bryant's motion documents the alleged cover-up paragraph by paragraph. Mace and her attorney D. Craig Brown dispute the allegations; no court has ruled on the motion.
On January 15, 2026, Patrick Bryant filed a motion in the Charleston County Court of Common Pleas asking the court to sanction Rep. Nancy Mace and her attorney, D. Craig Brown, under Rule 11 of the South Carolina Rules of Civil Procedure. The motion alleges that Mace's legal team submitted AI-generated fake case citations in a court brief opposing Bryant's motion for a temporary restraining order, and that when the problem was discovered, they tried to bury it rather than disclose it. The filed motion is reproduced in full below; the original PDF is available here.
The motion, as filed
Page 2 of 60, Exhibit B: the December 30, 2025 email from D. Craig Brown to Judge Hocker and counsel, attaching the Amended Memo with the explanation "I went back and updated citations in the memo."
Page 3 of 60, the motion's caption and opening: "DEFENDANT AND THIRD-PARTY PLAINTIFF PATRICK BRYANT'S MOTION FOR SANCTIONS AGAINST NANCY RUTH MACE AND HER COUNSEL D. CRAIG BROWN," Case No. 2025-CP-10-03124, Charleston County Court of Common Pleas, Ninth Judicial Circuit. The core allegation, fake AI-generated citations and concealment, appears in the opening notice paragraph.
Page 4 of 60, paragraphs 1-6: the timeline of the original Memo filed on the eve of the December 30 hearing, the Amended Memo circulated the next morning, and the allegation that "Mace's counsel did not inform the Court that the citations were updated because the initial citations were fabricated."
Page 5 of 60, paragraphs 7-15: the citation-by-citation breakdown. The O'Brien citation at 396 U.S. 367 leads to a different case entirely; the Island Packet quote is absent from both the original and corrected citation.
Page 6 of 60, paragraphs 15-22: further fabrications. The Columbia Newspaper quote is misquoted in both versions; the Greenville News pin-cite "only reaches page 6 of the S.C. Reporter" yet was cited to pages 7-8.
Page 7 of 60, paragraphs 22-29: the Amended Memo's last substitutions. The "clean hands" quote attributed to Jefferson Standard is a different partial quote than what appears in the motion's own citation of that case.
Page 8 of 60, paragraphs 30-34: the Rule 11 legal standard and the motion's sharpest allegation: that on December 30, Mace and Brown "were both aware of these concealments" yet "pressed the Court to hear the pending Motion for Temporary Restraining Order" in order to "skirt attention away from Mace and Brown's fabrications."
Page 9 of 60, paragraphs 35-36 and the Request for Sanctions. Bryant asks the court to order Mace and Brown to show cause and produce the Word documents for each memo, and requests fees. Signed January 15, 2026 by Nosizi Ralephata, Matthew Gallo, and William J. Blount of Gordon Rees Scully Mansukhani LLP, attorneys for Patrick Bryant.
What the filing says
Bryant's motion opens with its core allegation verbatim:
"Bryant moves for an order imposing sanctions pursuant to Rule 11, SCRCP against Third-Party Defendant Nancy Ruth Mace ('Mace') and her counsel, D. Craig Brown for using fake, AI generated citations in her Memorandum in Opposition to Bryant's Motion for a Temporary Restraining Order and attempting to conceal the fabrications from the Court by serving an Amended Memorandum which itself continued to use fabricated citations."
The motion details the alleged cover-up step by step. According to Bryant's filing, Mace's counsel filed the original brief on the eve of a December 30, 2025 hearing at which 14 motions were scheduled. The next morning, Brown circulated an amended version to the parties and the presiding judge, telling the court only: "I went back and updated citations in the memo." Bryant's motion alleges counsel said nothing about why:
"Mace's counsel did not inform the Court that the citations were updated because the initial citations were fabricated."
Bryant's motion further alleges that the amended brief did not fix the problem; it deepened it:
"Mace and her counsel were aware of the fake citations in the initial Memo, yet instead of bringing the issue to the parties and the Court's attention, acted to conceal the mistake by providing additional fabricated citations."
The motion documents the specific citations at issue. It alleges that multiple cases cited in the original brief either did not exist at the given citations or did not contain the legal propositions or quoted language attributed to them. When the amended brief substituted new citations, Bryant's motion contends that several of those replacements were also fabricated, real case names pointing to wrong volumes, non-existent pin-citations, and quoted language that cannot be found in the actual opinions. In one example, the motion alleges that an amended citation to U.S. v. O'Brien, 396 U.S. 367, points not to any O'Brien decision but to an entirely different case. In another, a quote attributed to Ex Parte Island Packet is alleged to be absent from both the original and corrected citation of that case.
What makes the motion particularly significant is the sequence it describes: the brief was filed the night before a major hearing, the amended version was handed to the judge at the hearing without any disclosure of what Bryant's motion describes as fabricated citations in the original, and, Bryant's motion alleges, the same hearing was pressed forward even as both Mace and Brown were aware the citations in both versions were problematic.
Bryant requests that the court order Mace and Brown to show cause and produce the underlying Word documents for each memorandum so the court can examine "the process by which these fabrications were presented before the Court." He also seeks an award of attorney's fees for the cost of identifying the fabrications and filing the sanctions motion.
These are allegations contained in a pending motion filed by Patrick Bryant; no court has ruled on them. Rep. Mace and attorney D. Craig Brown dispute the characterizations. The underlying litigation, Berg v. Bryant et al. (Case No. 2025-CP-10-03124) and related actions, remains contested, all parties deny wrongdoing, and none of the matters at issue has been adjudicated. The ongoing South Carolina State Law Enforcement Division (SLED) investigation is separate from this civil proceeding. Nothing here is a finding of fact. See People in the Public Record.
Sources & related coverage:
- The filing itself: Motion for Sanctions Against Nancy Ruth Mace and Her Counsel D. Craig Brown (PDF, 60 pages), Alexis Berg v. Patrick Bryant, John Osborne, Eric Bowman, Pommer Group LLC, Assignment Desk Works LLC and GLT2, LLC, Charleston County Court of Common Pleas, Ninth Judicial Circuit, Case No. 2025-CP-10-03124, filed January 15, 2026. Pages shown above are the motion itself (pp. 2-9 of 60); remaining pages are Exhibit A (text comparison of both memorandums) and Exhibit B (the email).
- The state docket is verifiable on the SC Judicial Branch Public Index (Charleston County) under Case No. 2025-CP-10-03124.
- Case background: The Litigation
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