Campbell v. TidalHealth, Inc.

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

One other consideration worth discussing is the potential misuse of generative artificial intelligence. The parties dedicate a substantial portion of their respective filings to whether Campbell’s motions involve improper use of or reliance on generative artificial intelligence, including whether she misstates legal authority or she uploaded confidential documents into a generative artificial intelligence program. ... Campbell denies submitting documents into any generative artificial intelligence tools but admits to using unspecified “available tools solely to express [her] arguments in proper legal format, the same way any litigant uses available legal resources.” ... Campbell’s filings bear common hallmarks of generative artificial intelligence, including their verbosity (more than 60 pages of briefing) about a relatively narrow issue, repeated statements that sound legally sophisticated while some of the legal citations are imprecise or inconsistent, and difficult to follow titles of her briefs. More concerning than those are any misrepresentations about the law. While the filings do not outright “hallucinate” any case, the citations do not support Campbell’s asserted propositions in the manner she attempts. For example, while Aguilar is a real case from the Southern District of New York (cited above and in the May 14 Order), the discussion at Campbell’s pincites does not say exactly what she represents. Also, her filings miss the mark in describing the import of this Court’s decision in Mancia. These could be viewed as a matter of (im)precision by a self-represented party lacking formal legal training rather than willful misleading or fabrication. In combination with other aspects of Campbell’s filings, they corroborate her admitted use of generative artificial intelligence. ... However, going forward, Campbell must exercise care in any use of generative artificial intelligence tools, to ensure that they do not generate any fictitious cases or, as best as she can determine, incorrect explanations of real cases. She is responsible for ensuring that the legal arguments presented in her filings are accurate and may not misrepresent the law to the Court. Further, the Court cautions that a failure to exercise such care could result in future sanctions, including an award of attorneys’ fees if future filings reflect bad faith or objectively improper arguments or authority.

Authorities cited in the passage: Aguilar v. Immigration & Customs Enforcement Division, 255 F.R.D. 350 (S.D.N.Y. 2008) · Mancia v. Mayflower Textile Services Co., 253 F.R.D. 354 (D. Md. 2008) · Kruglyak v. Home Depot U.S.A., Inc., 774 F. Supp. 3d 755 (W.D. Va. 2025) · United States v. Malik, 2025 WL 2687413 (D. Md. Sept. 19, 2025) · Fed. R. Civ. P. 11