AI-generated evidence and authentication

2026-08-18 · United States District Court for the Western District of Washington · provisional

The Western District of Washington grants summary judgment for Outliers and addresses AI-generated citation tables used in expert materials. The court recounts sanctions against counsel, finds Dr. Holguin’s hallucinated citations undermine his report’s reliability, and excludes that expert opinion under Rule 702 and Daubert.

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 …

2026-07-29 · United States Court of Appeals for the Tenth Circuit · provisional

The Tenth Circuit affirms dismissal of Shantell Robinson’s claims with prejudice as a Rule 11 sanction. The order describes nonauthentic evidence, at least four filings with nonexistent or misrepresented authority, and a new appellate brief citation to the nonexistent Reynolds v. Smith case.

The district court’s order detailed the clear and convincing evidence it relied on to determine that Ms. Robinson’s conduct was sanctionable. The court noted that despite her claims that her emergency motion was “grounded in fact,” Ms. Robinson submitted “no evidence to support the veracity of the purported intercepted statements” about Mr. Raines following her, …

2026-07-24 · United States District Court for the Western District of Washington · provisional

The Western District of Washington sanctions Jocelyn Stewart in the LeDoux litigation. The order finds Stewart used ChatGPT and Claude without verifying outputs, causing dozens of false citations across briefs and expert reports, and imposes a $3,000 personal sanction plus future citation certifications.

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. ... …

2026-07-17 · U.S. Court of Appeals for the Third Circuit

On 2026-07-17, the Third Circuit affirms dismissal of a civil-rights suit alleging police and prosecutors fabricated or altered body-camera footage with artificial intelligence. The court holds the appeal forfeited and, alternatively, agrees that Heck, limitations, and other grounds bar the claims.

Bryan filed this civil rights action under 42 U.S.C. § 1983. He alleges that the City of Philadelphia, Philadelphia Police Department, some of its officers, the Philadelphia District Attorney Office, the Philadelphia District Attorney, and various Assistant District Attorneys violated his civil rights in conjunction with a 2022 arrest and 2023 prosecution. According to Bryan, …

2026-03-18 · U.S. District Court for the Eastern District of Virginia · provisional

On 2026-03-18, the Eastern District of Virginia enforces a settlement agreement after an evidentiary hearing. The plaintiff argued an audio recording was AI-cloned or manipulated; the court applied Rule 901, found the recording authentic, credited voice-identification evidence, and rejected the authentication challenge.

Walburn maintains that Burnley, using the pseudonym “Tyrone Jackson,” materially breached the Walburn-Burnley Settlement Agreement’s express prohibition against contacting Walburn’s employers about Walburn. In defense, Burnley denies calling Walburn’s current employer and claims that the Court cannot assume it was him based on voice comparison alone. He adds that any connection to a former neighbor …

2026-02-17 · New York Court of Appeals · 2026 NY Slip Op 00825

On 2026-02-17, the New York Court of Appeals reverses Family Court abuse findings based solely on videos obtained from a third party. The court holds the authentication foundation insufficient and discusses how deepfake technology makes circumstantial matching of places and people less reliable.

Investigator Mahoney’s testimony that the videos matched his personal observations of the layout of the living room and items he observed there are similarly insufficient and are not meaningfully different from what we rejected in Patterson. There, an officer who had visited the store where the robbery occurred testified that the video was an accurate …

2025-10-09 · U.S. District Court for the Western District of Washington · provisional

On 2025-10-09, the Western District of Washington denies requests for counsel and a neutral expert. The plaintiff alleged police used AI to create deepfake body-camera footage, but the court found only assertions of tampering and ruled Rule 706 did not support appointing an expert at that stage.

Plaintiff raises claims relating to events leading up to and occurring on the date of his September 2023 arrest by officers of the Bellingham Police Department. See Dkt. 38. He asserts, as central to his claims and relevant to the pending motions, that Defendants engaged in a conspiracy to intentionally assault him and then alter …

2025-10-07 · 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 …