Williams v. Capital One Bank
D. DC · Mar 18, 2025
- Jurisdiction
- federal
- Court
- D. DC
- Record ID
- williams-v-capital-one-bank-2025-03-18
- Observed outcome
- The court granted the defendant's motion to dismiss the complaint with prejudice and issued a formal warning to the plaintiff regarding the use of fabricated citations.
- Known monetary consequence
- $0
Why this matter warrants attention
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.
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.
Even CoCounsel output triggers dismissal with prejudice when unverified — paid tools carry the same verification duty as consumer ones.
Failure modes and consequences
- Hallucination
- Fabricated_case_law
- Misattributed_authority
- Pro Se
- Fake Citations
- Misrepresented Authority
- AI attribution
- Explicitly Recorded
- Recorded tool
- CoCounsel
- Known monetary consequence
- $0
- Procedural posture
- 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.
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
The court identified the use of CoCounsel.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to CoCounsel output as to any other research input.