LeDoux v. Outliers, Inc.

What the court wrote

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

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. Jocelyn Stewart, to show cause and explain why she should not be sanctioned for these errors. ... Ms. Stewart filed a sworn declaration on March 4, explaining that she had used two artificial intelligence programs—ChatGPT and Claude—to generate the false citations, that she was unaware of any falsities when she submitted the documents, and that she “accept[s] full responsibility for the errors” and has “changed [her] practices to ensure this does not happen again.” ... On February 4, 2026, the Court found that Ms. Stewart “submitted dozens of inaccurate factual and legal citations across at least five different filings.” 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. ... She avers that she used Claude and ChatGPT to draft her submissions in this case, that these programs generated the false citations identified in the Court’s order, and that she “did not verify the output against the source before filing.” ... Here, Ms. Stewart’s actions warrant significant sanctions. Ms. Stewart submitted dozens of false citations throughout four briefs and two expert reports. ... The Court thus finds that the below sanctions are necessary to address Ms. Stewart’s conduct. 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. ... 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.

Authorities cited in the passage: Fed. R. Civ. P. 11(b) · Washington State Bar Association Advisory Opinion 202505 · Chaney v. Transdev Services Inc., 2026 WL 1146736 (C.D. Cal. Apr. 28, 2026) · Gerke v. Travelers Casualty Insurance Co. of America, 289 F.R.D. 316 (D. Or. 2013) · Parker, 2025 WL 4228413