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Discovery and AI-assisted review

Orders on generative AI in document review, technology-assisted review protocols and AI-assisted privilege logs. 6 decisions from 6 courts, newest first; 3 read in full from the court's copy.

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub

  1. Campbell v. TidalHealth, Inc.

    · United States District Court for the District of Maryland · provisional

    The District of Maryland denies discovery sanctions in a pro se employment case and addresses possible generative-AI misuse. The court says Campbell’s filings do not outright hallucinate cases but misdescribe Aguilar and Mancia, corroborating admitted tool use, and cautions that future errors may draw fees or sanctions.

    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. ... …
  2. Schulte v. LinkedIn Corp.

    · U.S. District Court for the Northern District of California

    On 2026-07-01, the Northern District of California resolves discovery disputes over LinkedIn’s use of Relativity aiR. The court permits search-string pre-culling before GenAI review and denies additional audit metrics, finding LinkedIn’s disclosures satisfied the interim ESI order absent a specific deficiency.

    On May 15, 2026, LinkedIn provided the plaintiffs with twenty-five search strings to be applied against LinkedIn’s custodial documents. At the same time, LinkedIn informed the plaintiffs that it would be using Relativity aiR, a GenAI review tool, “to assist in filtering out non-responsive documents.” On May 23, 2026, the plaintiffs requested more information about …
  3. Morgan v. V2X, Inc.

    · U.S. District Court for the District of Colorado

    On 2026-03-30, the District of Colorado amends a protective order in an employment case involving a pro se plaintiff’s AI use. The court protects party work product, requires disclosure of the AI platform used with confidential information, and bars uploads to tools lacking contractual safeguards.

    Here, like in Warner v. Gilbarco, Inc., 2026 WL 373043 (E.D. Mich. Feb. 10, 2026), Plaintiff can assert work product protections in connection with his AI use. It is true that AI systems like ChatGPT, Claude, Gemini, and others widely available to the public, collect user data for training and other purposes. But in this …
  4. Warner v. Gilbarco, Inc.

    · U.S. District Court for the Eastern District of Michigan · 2026 WL 373043 · provisional

    On 2026-02-10, the Eastern District of Michigan denies defendants’ bid to compel a pro se plaintiff’s AI-use materials. The court holds the requested materials are not discoverable and, in any event, are protected work product; using ChatGPT does not waive that protection.

    To the extent Defendants seek production of “all documents and information concerning her use of third-party AI tools in connection with this lawsuit, as requested in Defendants’ discovery requests,” this request is DENIED, as the information sought is not discoverable. See Fed. R. Civ. P. 26(b)(3)(A) (“Ordinarily, a party may not discover documents and tangible …
  5. Demissie v. Ford

    · U.S. District Court for the District of Nevada · provisional

    On 2025-10-07, the District of Nevada denies a protective order seeking to postpone a deposition. The plaintiff alleged produced body-worn camera footage contained deepfake edits and feared a recorded deposition could be manipulated, but the court found no reliable evidence of alteration.

    The Motion argues that Plaintiff’s deposition cannot proceed because Plaintiff has a pending Motion for Terminating Sanctions (ECF No. 71) alleging fraud on the Court based on the unrelenting theme that Las Vegas Metropolitan Police Department (“Metro”) produced fabricated body worn camera footage. Id. at 1. Plaintiff further contends Metro is withholding critical discovery including …
  6. Berger v. Graf Acquisition, LLC

    · Delaware Court of Chancery

    On 2024-10-21, the Delaware Court of Chancery grants in part a motion to compel in SPAC litigation. To address burden from broad document requests, the court permits defendants to use a technology-assisted review protocol with attorney involvement and transparency to the plaintiff.

    Fortunately, the defendants also propose a reasonable means to address their burden concerns: a technology assisted review (TAR). That is, the defendants are willing to review the universe of documents captured by the plaintiff’s broad search terms so long as they can employ a TAR protocol. But the plaintiff rejected this offer and insists that …