The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 269, 18 August 2026 · source · PDF · 19 pages
Docket text. ORDER: The Court GRANTS Defendants Daubert motions. Dkts. 206, 208.The Court GRANTS Defendants motion for summary judgment. Dkt. 207. Plaintiffs remaining claims are DISMISSED WITH PREJUDICE. Signed by District Judge Tiffany M. Cartwright.(PS)
Defendants argue that Dr. Holguin’s opinion (1) is irrelevant because it concerns only claims which the Court has already dismissed and (2) is unreliable because it contains citations “hallucinated” by artificial intelligence. Dkt.
But Dr. Holguin’s report also contains “hallucinated” citations to academic articles which appear generated by artificial intelligence. Dkt.
ORDER GRANTING DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT - The Court agrees with Defendants and finds that Dr. Holguin’s multiple hallucinated citations “shatter[] his credibility with this Court.” Kohls v. Ellison, No.
May 23, 2025). The Court finds that the hallucinated citations undermine Dr. Holguin’s entire report and that the report is not reliable under Daubert.
Docket entry 265, 24 July 2026 · source · PDF · 11 pages
Docket text. ORDER ON SANCTIONS. The Court ORDERS the following sanctions for violation of Federal Rule of Civil Procedure 11(b): 1. Attorney Jocelyn Stewart is personally sanctioned in the amount of $3,000. Within 21 days of the date of this order, Ms. Stewart shall pay this sanction to the Clerk of the Court. The case number and a copy of this order should be included with payment. 2. Ms. Stewart shall include a certification with all subsequent briefing in this case stating that all citations have been verified and accurately reflect the propositions put forth. 3. Ms. Stewart shall provide a copy of this order to Plaintiff Joann LeDoux and file a certification with the Court that she has done so no later than July 28, 2026. 4. The order to show cause issued on February 4, 2026 (Dkt. 209 ) is hereby discharged. Signed by District Judge Tiffany M. Cartwright. (BKP) (cc: WAWD Finance)
3:24-cv-05808-TMC ORDER ON SANCTIONS I. INTRODUCTION In November and December 2025, Plaintiff Joann LeDoux submitted multiple filings containing dozens of inaccurate factual and legal citations which appeared “hallucinated” by a generative artificial intelligence tool. On February 4, 2026, the Court ordered Plaintiff’s counsel, Ms.
184. During that hearing, Defendants raised concerns that Plaintiff’s recently-filed Daubert motion was “littered” with citations Defendants believed to be false and hallucinated by artificial intelligence. Dkt.
209 at 6. These errors included citations to nonexistent sources, as well as fictitious quotations from real sources. Concerningly, two of Plaintiff’s expert reports contained citations to the same nonexistent or misattributed academic articles.
Although Ms. Stewart had attempted to correct hallucinated citations in her Daubert motion, the Court found that “[h]er explanations and corrections [were] incomplete at best and misleading at worst.” Id. at 5. For example, “Plaintiff’s ‘corrected’ Daubert motion replaced some false quotations with real ones but, in doing so, 1 The Court discussed the facts of this case in detail when it addressed the motions for partial summary judgment and will not do so again here.
Specifically, the Court required Ms. Stewart to submit a sworn declaration and: (1) detail all incorrect, misleading, or nonexistent citations and all incorrect or misleading assertions submitted to this Court; (2) provide a thorough explanation for how the incorrect citations discussed in this order were found or generated; and (3) to the extent that she used any artificial intelligence programs in preparing the submissions discussed in this order or any other submissions to this Court, Plaintiff’s counsel shall include the names of those programs in her declaration. Id.
Stewart did little to remedy her errors. She submitted an additional hallucinated citation to this Court on December 18, over two weeks after learning that her citations in other briefs might have been erroneous. Dkt.
1990)). Sanctions for fabricated citations may include “(1) monetary sanctions, (2) striking the filing containing erroneous citations, (3) requiring written notification to the client, (4) requiring written notification to judges incorrectly identified as having authored nonexistent cases, and (5) referring attorneys to the appropriate disciplinary body for disciplinary proceedings.” Oneto, 808 F. Supp.
Dec. 17, 2025) (imposing no sanctions where an attorney “openly and honestly admitted to his improper use of AI, including the submission of hallucinated citations” and “took the initiative to self-report to the State Bar for his improper use of AI and contend[ed] that he [was] reviewing all other pending matters”). Here, Ms.
Docket entry 262, 8 July 2026 · source · PDF · 8 pages
Docket text. ORDER denying Plaintiff's 215 Motion for lesser sanctions, which this Court construes as a motion for reconsideration. Signed by District Judge Tiffany M. Cartwright. (BKP)
Id. at 12–13. Parallel to the parties’ summary judgment briefing, Defendants expressed concerns that Plaintiff’s submissions, including her expert reports, contained false citations that were “hallucinated” by a generative artificial intelligence program. Dkt.
Docket entry 209, 4 February 2026 · source · PDF · 7 pages
Docket text. ORDER TO SHOW CAUSE. The Court ORDERS Plaintiff's counsel to SHOW CAUSE in writing by February 25, 2026, why she should not be sanctioned pursuant to Rule 11. Plaintiff's counsel shall (1) detail all incorrect, misleading, or nonexistent citations and all incorrect or misleading assertions submitted to this Court; (2) provide a thorough explanation for how the incorrect citations discussed in this order were found or generated; and (3) to the extent that she used any artificial intelligence programs in preparing the submissions discussed in this order or any other submissions to this Court, Plaintiff's counsel shall include the names of those programs in her declaration. Signed by District Judge Tiffany M. Cartwright. (BKP) (Entered: 02/04/2026)
To the extent attorneys use these tools, they remain bound by Rule 11 to submit truthful legal and factual contentions. Plaintiff’s briefs contain multiple incorrect citations which bear “the emblems of the use of a generative artificial intelligence tool,” which can “fabricate or ‘hallucinate’” legal precedent and factual assertions. Romero v.
Plaintiff’s proposed amended complaint (Dkt. 173-1) • Plaintiff quotes text from RCW 7.72.010(2) which does not exist. Dkt.
Plaintiff’s Daubert motion (Dkt. 176) 1 • Plaintiff submitted over a dozen quotes from various expert reports which do not exist. Defendants provided a table describing the faulty citations in their response to the Daubert motion.
25, 2025)). Plaintiff includes two quotes which do not exist in Fair. See Dkt.
See Dkt. 178 at 12 (“jurisdictional bar”), 19–20 (“the better rationale for striking lies in the fact that the purported defense amounts to nothing more than a denial of liability”). • Plaintiff quotes language which does not exist in In re Washington Mut., Inc. Sec., Derivative & ERISA Litig., 694 F.
Dkt. 178 at 20 (“unclean hands”). • Plaintiff quotes language which does not exist from another order in In re Washington Mut. 2011 WL 1158387, at *2 (W.D.
194-13) ORDER TO SHOW CAUSE - • Mr. Kababick’s expert report cites several articles which do not exist or are attributed to the wrong author. Dkt.
Plaintiff’s response to Defendants’ motion to exclude expert evidence (Dkt. 197) • Plaintiff quotes language which does not exist in HSS Enters. v. AMCO Ins., 2008 U.S.