Courts on AI / Fabricated or misquoted citations
Laud Essandoh v. Capital One Bank NA
United States District Court for the Eastern District of Texas · Federal district courts · TX · · 2026 WL 1040383 · 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
- The court admonished the self-represented plaintiff and imposed disclosure and certification requirements for any future generative-AI use.
- Recorded conduct
- The self-represented plaintiff submitted an inaccurate joint discovery report after relying on generative AI without adequate verification. — outcome: warning; actor: litigant in person
- 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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