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Essandoh v. Capital One Bank NA

United States District Court for the Eastern District of Texas, Sherman Division · Federal district courts · TX · · 2026 WL 1040383 · No. No. 4:25-CV-00746-ALM-BD · order

The Eastern District of Texas on 2026-04-16 admonished the self-represented plaintiff about inaccuracies in a joint discovery report caused by generative-AI reliance. The order required future disclosures identifying any generative-AI use and certifications that the filer reviewed AI work product for accuracy and relevance.

Disposition
After admonishing Essandoh at a discovery hearing, the court ordered disclosure and certification requirements for any future filing prepared with AI and described possible sanctions for violations.
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

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

LAUD ESSANDOH v. United States District Court, E. D. Texas, Sherman Division. LAUD ESSANDOH v. CAPITAL ONE BANK NA NO. ORDER ON DISCLOSURE AND CERTIFICATION REQUIREMENTS FOR USE OF GENERATIVE ARTIFICIAL INTELLIGENCE Bill Davis United States Magistrate Judge *1 Today, the court held a discovery hearing based on the parties' joint report, Dkt. 25, following the court's face-to-face order, Dkt. 24. Minute Entry for Apr. 16, 2026. At the hearing, the court questioned plaintiff Laud Essandohregardinginaccuraciesinhispartofthejointreport. Id. Essandoh admitted that the inaccuracies resulted from reliance on generative artificial intelligence (“AI”). Id. The court admonished him about the risks of that misplaced relianceandthesanctionsthatcanresultfromit. Id.

Authorities cited in the passage: Sherman Division. LAUD ESSANDOH v. CAPITAL ONE BANK NA NO. ORDER ON DISCLOSURE AND CERTIFICATION REQU

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