Tlingit Haida Tribal Business Corporation v. OnePromom
D. Colorado · Jun 9, 2026
- Jurisdiction
- federal
- Court
- D. Colorado
- Record ID
- tlingit-haida-tribal-business-corporation-v-onepromom-2026-06-09
- Observed outcome
- The 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 monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fabricated Quotes
- Contract
- Trial
- Ordered To Show Cause
- AI attribution
- Admitted
- Recorded tool
- Eve Legal
- Known monetary consequence
- Not recorded
- Procedural posture
- Order to show cause issued on June 9, 2026, following a motion to dismiss.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel certified the use of Eve Legal in the motion.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Apply the same source-checking controls to Eve Legal output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.