LeDoux v. Outliers, Inc.

What the court wrote

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

The Court also issued sua sponte sanctions against Plaintiff’s attorney, Ms. Jocelyn Stewart, for generating numerous false citations with artificial intelligence and submitting them to the Court without verification. Dkt. 265. Multiple such citations existed in the expert reports of Mr. James Kababick and Dr. Ronald Shippee, where Plaintiff admitted that “she used Claude or ChatGPT to ‘generate a formatted citation table’ for academic articles and ‘provided the same AI-generated citation table to both experts as an appendix, and neither expert caught the errors in the citation data before signing their reports.’” Dkt. 265 at 7 (quoting Dkt. 245 at 17–18). ... The Court agrees with Defendants and finds that Dr. Holguin’s multiple hallucinated citations “shatter[] his credibility with this Court.” Kohls v. Ellison, No. 24-CV-3754 (LMP/DLM), 2025 WL 66514, at *4 (D. Minn. Jan. 10, 2025). ... This level of involvement from counsel in drafting (with AI) the list of materials supposedly relied upon by Dr. Holguin, and Dr. Holguin’s lack of diligence in verifying the sources that he represented were the basis for his opinion, prevent Plaintiff from meeting her burden to show that Dr. Holguin’s opinion is “based on sufficient facts or data,” is “the product of reliable principles and methods,” or “reflects a reliable application of the principles and methods to the facts of the case.” Fed. R. Evid. 702(b)–(d).

Authorities cited in the passage: Dkt. 265 · Dkt. 245 · Kohls v. Ellison, 2025 WL 66514 (D. Minn. Jan. 10, 2025) · Concord Music Group, Inc. v. Anthropic PBC, 2025 WL 1482734 (N.D. Cal. May 23, 2025) · Fed. R. Evid. 702