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Reason
Reason
Eugene Volokh

"Whoever or Whatever Drafted the Briefs Signed and Filed by Blackburn,"

From today's decision by Judge William Stickman IV (W.D. Pa.) in Jakes v. Youngblood (note that the lawyer, Tyrone Blackburn, "was arrested Wednesday and accused of hitting a process server with his car in New York City," in seemingly an otherwise unrelated matter [NBC News, Marlene Lenthang]):

Defendant Duane Youngblood ("Youngblood") filed a Notice of Motion to Dismiss, a supporting brief, and a reply brief requesting the dismissal of Plaintiff Thomas Dexter Jakes' ("Jakes") complaint with prejudice. Youngblood is represented by Attorney Tyrone A. Blackburn ("Blackburn"), the signatory of the motion and briefs…. 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.

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 brief 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." 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. 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. On June 25, 2025, Blackburn filed a Withdrawal of Appearance….

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 Court's 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. By way of example, the following italicized portions of Blackburn's brief supporting the motion to dismiss represent a sampling of the fabricated quotes:

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