Williams v. Capital One Bank
D. DC · Mar 18, 2025
What happened in this matter?
The court dismissed the plaintiff's complaint with prejudice for failure to state a claim and issued a formal warning regarding the use of AI-generated fabricated case citations. The court did not impose monetary sanctions but mandated that the plaintiff notify other courts of any similar errors in his pending filings.
- Why the court cared
- The court reasoned that the plaintiff's reliance on AI-generated, non-existent citations weakened his opposition and violated the standard for acceptable filings. It determined that the burden of verifying citations rests with the filing party, regardless of whether AI tools were used. The court further concluded that dismissal with prejudice was appropriate because the plaintiff had previously been granted an opportunity to amend his complaint and failed to cure factual deficiencies.
- Why it matters now
- Even CoCounsel output triggers dismissal with prejudice when unverified — paid tools carry the same verification duty as consumer ones.
Why this matter is tracked
Fabricated: Case Law | Plaintiff cited a non-existent case; the court confirmed no such case exists. Outcome: Case dismissed with prejudice for failure to state a claim. No monetary sanction imposed, but the court issued a formal warning.
AI Use
While not formally admitted, Plaintiff’s opposition brief referred to “legal generative AI program CoCounsel,” and the court noted that the structure and citation pattern were consistent with AI-generated output. Capital One was unable to verify several case citations, prompting the court to scrutinize the submission.
Hallucination Details
At least one case was fully fabricated, and another was a real case misattributed to the wrong jurisdiction and reporter. The court emphasized that it could not determine whether the mis-citations were the result of confusion, poor research, or hallucinated AI output—but the burden rested with the party filing them.
Ruling/Sanction
The court dismissed the complaint with prejudice, noting Plaintiff had already filed and withdrawn a prior version and had had full opportunity to amend. Though it did not impose monetary sanctions, it issued a strong warning and directed Plaintiff to notify other courts where he had similar pending cases if any filings included erroneous AI-generated citations.
Even CoCounsel output triggers dismissal with prejudice when unverified — paid tools carry the same verification duty as consumer ones.
Record details
What the record establishes about AI use
The court identified the use of CoCounsel.
The court granted the defendant's motion to dismiss the complaint with prejudice following the plaintiff's submission of an opposition brief containing fabricated legal authority.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff cited a non-existent case; the court confirmed no such case exists.
- Misrepresented: Case Law | Plaintiff cited an existing case with an incorrect reporter citation; the cited volume/page corresponds to a different N.D. Cal. case, and it is unclear which Equifax case was intended.
Questions this record answers
- What happened in Williams v. Capital One Bank?
- The court dismissed the plaintiff's complaint with prejudice for failure to state a claim and issued a formal warning regarding the use of AI-generated fabricated case citations. The court did not impose monetary sanctions but mandated that the plaintiff notify other courts of any similar errors in his pending filings.
- Why does Williams v. Capital One Bank matter for legal AI risk?
- Even CoCounsel output triggers dismissal with prejudice when unverified — paid tools carry the same verification duty as consumer ones.
- What does the public record establish about Williams v. Capital One Bank?
- 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 Williams v. Capital One Bank 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.