Law360 (May 11, 2026, 4:52 PM EDT) -- The attorney for a woman who has accused Sean "Diddy" Combs of rape was found in contempt of court Monday for failing to make payments on a $6,000 fine imposed on the lawyer in December for relying on a hallucinated artificial intelligence case citation in a legal brief.

U.S. Court of International Trade Judge Leo M. Gordon, sitting by designation in the District of New Jersey, said multiple disciplinary options were available, including sending Tyrone A. Blackburn of T.A. Blackburn PLLC to jail, imposing an additional financial penalty or delivering a written warning. But the judge took a different tack.

"I am going to hold you in contempt," Judge Gordon said, "but I am going to issue an oral admonition."

After saying Blackburn's "conduct and behavior is lacking," the jurist offered this advice: "If you have to stop and ask yourself if what you are doing is appropriate, then you know the answer to the question."

Judge Gordon noted that this was the second show-cause hearing for Blackburn, with the first coming in December after Blackburn used a made-up case from AI in a brief then failed to correct the error after it was pointed out to him by opposing counsel and the court.

At that point, he was ordered to pay a $6,000 penalty in monthly installments of $500 beginning in March. But so far no payments have been received by the court, the judge said.

"This is your last oral warning," Judge Gordon said. "This is your last warning, period."

Blackburn said he had sent one payment to the court and presented a certified mail receipt as evidence.

"It's not that I don't want to pay," Blackburn said. "I just didn't have the resources at the time. That's the long and the short of it. Thank you for your patience."

The jurist said he was persuaded, in part, to avoid a harsher disciplinary action by the presence of two lawyers in the courtroom, Marjorie Mesidor of Mesidor PLLC and Heather M. Palmore of Palmore Law Group PC, who will join Blackburn in representing Liza Gardner. Mesidor said she would be lead counsel for the case.

In addition, Mesidor said that in the interest of keeping the underlying case moving forward, the new counsel would make arrangements to pay the financial penalty that was imposed on Blackburn in December.

The December sanctions stemmed from Blackburn's opposition to dismissal motions filed by Combs, Uptown Records and Universal Music Group. In that brief, Blackburn repeatedly cited "United States v. Masha," purportedly a 2021 Seventh Circuit decision interpreting the Mann Act. The case does not exist.

Defense counsel flagged the issue in a footnote, noting they were "unable to locate a case with this citation." At oral argument, Judge Gordon convened an off‑the‑record sidebar to determine whether the citation was a typographical error or an AI‑generated fabrication. Blackburn later acknowledged that he had used generative AI to assist with research, that the tool produced the nonexistent case, and that he failed to verify the citation before filing or catch the error in preparing for argument.

In the December order, Judge Gordon found that Blackburn violated Rule 11 and that the error was part of a broader pattern of negligent research practices and missed deadlines in multiple jurisdictions. In addition to the monetary sanction and self‑reporting requirement, the judge ordered Blackburn to provide his client with copies of the sanctions order, the underlying filings and the transcript of the show‑cause hearing.

Gardner's suit, removed to federal court in July 2024, alleged that Combs and singer Aaron Hall raped her in 1990 when she was a teenager visiting members of R&B group Jodeci, which Combs was then "developing" as an Uptown Records employee. Hall is also named as a defendant.

In January, Judge Gordon dismissed claims against Universal Music Group and UMG Recordings Inc., finding the court lacked jurisdiction because the entities did not exist in 1990 and could not be considered successors to Uptown or MCA Records. He also dismissed a negligent infliction of emotional distress claim against Combs for lack of a duty of care. But he allowed two assault and battery claims to proceed under an amended version of New Jersey's Child Sexual Abuse Act, which revives certain time‑barred claims involving minors.

A default judgment motion against Hall remains pending.

Combs, for his part, is current serving a 50-month prison sentence after a Manhattan federal jury found him guilty in July 2025 of transporting two former girlfriends for prostitution, but cleared him on more serious charges of racketeering and sex trafficking. He's pursuing an appeal in the Second Circuit.

Gardner is represented by Tyrone A. Blackburn of T.A. Blackburn PLLC.

Combs is represented by Yonatan Y. Jacobs, Erica A. Wolff, Michael Tremonte and Katie Renzler of Sher Tremonte LLP.

Universal Music Group and UMG Recordings are represented by Greer Griffith, Edward B. Diskant, Lisa A. Linsky, Max J. Kellogg and Elizabeth A. Rodd of McDermott Will & Schulte LLP.

Counsel information for Hall was not available.

The case is Gardner v. Combs et al., case number 2:24-cv-07729, in U.S. District Court for the District of New Jersey.

--Editing by Amy French.

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