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HomeCasesTlingit Haida Tribal Business Corporation v. OnePromom
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Corpus matter record

Tlingit Haida Tribal Business Corporation v. OnePromom

D. Colorado · Jun 9, 2026

CO / federalEditorial impact: mediumfabricated quotescontracttrialOrdered To Show Cause
Direct answer

What happened in this matter?

The court issued an order to show cause against defense counsel Marianna McLean for attributing an inaccurate, expanded quotation to Seale v. Peacock in a motion to dismiss. Despite counsel's certification that she used Eve Legal and manually reviewed all cited authority, the court found the misrepresentation of case law to be a violation of the duty to accurately quote authorities.

Why the court cared
The court reasoned that counsel has a fundamental duty to ensure accurate quotations. The court found the misrepresentation particularly concerning because counsel explicitly certified that she had manually reviewed all cited authority despite the error.
Why it matters now
This case highlights the risk of 'automation bias' where counsel relies on AI-generated research and fails to perform the promised manual verification, leading to court-ordered show cause proceedings for misrepresenting legal authority.

Why this matter is tracked

In a contract dispute, defense counsel submitted a motion to dismiss containing an inaccurate, expanded quotation attributed to Seale v. Peacock. The court noted that the language did not appear in the cited case and overrepresented the holding. Counsel had certified that the filing was drafted using the AI tool Eve Legal and that all cited authority had been manually reviewed. Finding the misrepresentation troubling given the manual review certification, the court ordered defense counsel to show cause why the inclusion of the inaccurate quotation does not violate Rule 11(b) and why she should not be sanctioned under Rule 11 or 28 U.S.C. § 1927.

Operational lesson

This case highlights the risk of 'automation bias' where counsel relies on AI-generated research and fails to perform the promised manual verification, leading to court-ordered show cause proceedings for misrepresenting legal authority.

Record details

ColoradoSingle-state evidence scope
Explore COOpen its source-linked jurisdiction page and related matters.
CourtD. Colorado
Jurisdictionfederal
Circuit10th Circuit
DateJun 9, 2026
EV
AI toolEve Legal
Party typeLawyer
OutcomeThe court granted in part and denied in part the motion to dismiss and ordered defense counsel to show cause regarding potential Rule 11 or § 1927 sanctions.
Known amountNot recorded
Professional sanctionCounsel ordered to show cause regarding potential sanctions under Rule 11 and 28 U.S.C. § 1927.
Attribution boundary

What the record establishes about AI use

admitted

Counsel certified the use of Eve Legal in the motion.

Procedural posture

Order to show cause issued on June 9, 2026, following a motion to dismiss.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

1 citation, quotation, or authority issues are recorded in the source dataset.

  1. False Quotes: Case Law | Defense counsel attributed an inaccurate, expanded quotation to Seale v. Peacock; the language does not appear in Seale and overstates its holding.

Questions this record answers

What happened in Tlingit Haida Tribal Business Corporation v. OnePromom?
The court issued an order to show cause against defense counsel Marianna McLean for attributing an inaccurate, expanded quotation to Seale v. Peacock in a motion to dismiss. Despite counsel's certification that she used Eve Legal and manually reviewed all cited authority, the court found the misrepresentation of case law to be a violation of the duty to accurately quote authorities.
Why does Tlingit Haida Tribal Business Corporation v. OnePromom matter for legal AI risk?
This case highlights the risk of 'automation bias' where counsel relies on AI-generated research and fails to perform the promised manual verification, leading to court-ordered show cause proceedings for misrepresenting legal authority.
What does the public record establish about Tlingit Haida Tribal Business Corporation v. OnePromom?
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 Tlingit Haida Tribal Business Corporation v. OnePromom 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.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

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