Joann LeDoux v. Outliers, Inc.
W.D. Wash. · Aug 18, 2026
What happened in this matter?
Fabricated: Other | AI-generated formatted citation table appended to expert reports of James Kababick and Ronald Shippee contained numerous false/fabricated academic citations; plaintiff admitted providing the same AI-generated citation table to both experts. Outcome: Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations.. Plaintiff's counsel used generative AI (Claude and ChatGPT) to produce a formatted citation table appended to expert reports, which contained numerous fabricated/false academic citations. The Court found these AI-generated citations undermined expert credibility, sanctioned counsel sua sponte, and excluded expert testimony (notably Dr. Holguin) as unreliable under Daubert because the hallucinated citations showed lack of verification and shattered credibility. The Court relied on counsel's admitted use of AI and the similarity of errors across expert reports in reaching these conclusions.
- Why the court cared
- The structured public record identifies fake citations and trial and records Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations.. The linked source controls the precise reasoning and procedural context.
- Why it matters now
- This matter connects fake citations and trial with Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations. in W.D. Wash.. It provides a source-linked baseline for verification, supervision, and response controls.
Why this matter is tracked
Fabricated: Other | AI-generated formatted citation table appended to expert reports of James Kababick and Ronald Shippee contained numerous false/fabricated academic citations; plaintiff admitted providing the same AI-generated citation table to both experts. Outcome: Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations.. Plaintiff's counsel used generative AI (Claude and ChatGPT) to produce a formatted citation table appended to expert reports, which contained numerous fabricated/false academic citations. The Court found these AI-generated citations undermined expert credibility, sanctioned counsel sua sponte, and excluded expert testimony (notably Dr. Holguin) as unreliable under Daubert because the hallucinated citations showed lack of verification and shattered credibility. The Court relied on counsel's admitted use of AI and the similarity of errors across expert reports in reaching these conclusions.
This matter connects fake citations and trial with Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations. in W.D. Wash.. It provides a source-linked baseline for verification, supervision, and response controls.
Record details
What the record establishes about AI use
Claude and ChatGPT is recorded in the source dataset; confirm the basis in the linked document.
Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Other | AI-generated formatted citation table appended to expert reports of James Kababick and Ronald Shippee contained numerous false/fabricated academic citations; plaintiff admitted providing the same AI-generated citation table to both experts.
- Fabricated: Other | Dr. Gabriel Holguin's expert report contained multiple AI-generated fabricated citations to academic articles in portions later withdrawn; the Court found these hallucinated citations undermined his credibility and rendered his opinions unreliable.
- Fabricated: Exhibits & Submissions | Plaintiff's counsel (Jocelyn Stewart) used Claude or ChatGPT to generate citation data provided as an appendix/submission to the court and experts, resulting in numerous false citations in filings and expert exhibits.
Questions this record answers
- What happened in Joann LeDoux v. Outliers, Inc.?
- Fabricated: Other | AI-generated formatted citation table appended to expert reports of James Kababick and Ronald Shippee contained numerous false/fabricated academic citations; plaintiff admitted providing the same AI-generated citation table to both experts. Outcome: Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations.. Plaintiff's counsel used generative AI (Claude and ChatGPT) to produce a formatted citation table appended to expert reports, which contained numerous fabricated/false academic citations. The Court found these AI-generated citations undermined expert credibility, sanctioned counsel sua sponte, and excluded expert testimony (notably Dr. Holguin) as unreliable under Daubert because the hallucinated citations showed lack of verification and shattered credibility. The Court relied on counsel's admitted use of AI and the similarity of errors across expert reports in reaching these conclusions.
- Why does Joann LeDoux v. Outliers, Inc. matter for legal AI risk?
- This matter connects fake citations and trial with Court issued sua sponte sanctions against Plaintiff's counsel for submitting AI-generated false citations; excluded expert Dr. Gabriel Holguin for unreliability and excluded/struck other expert evidence tied to the false citations. in W.D. Wash.. It provides a source-linked baseline for verification, supervision, and response controls.
- What does the public record establish about Joann LeDoux v. Outliers, Inc.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Joann LeDoux v. Outliers, Inc. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
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