US District Court, Western District of Washington (Judge Tiffany M. Cartwright)
LeDoux v. Outliers, Inc. (d/b/a Thesis), No. 3:24-cv-05808-TMC
Sanctioned · 24 July 2026
What was fabricated
Dozens of inaccurate factual and legal citations across at least four filings by counsel, including citations to nonexistent sources and fictitious quotations attributed to real, existing sources. Counsel generated a formatted citation table using Claude and ChatGPT. ⚠️ THE SAME AI-GENERATED TABLE WAS SUPPLIED TO TWO TESTIFYING EXPERTS AS AN APPENDIX and is the origin of the fabrications in their reports; neither expert caught the errors before signing. Those reports are recorded separately — see `2026-08-ledoux-kababick-expert-wdwash` — but the fabrication in all of them is counsel's. Split from a single bundled row on 7 Sep 2026 under the matter-vs-document ruling.
What happened as a result
Attorney Jocelyn Stewart personally sanctioned $3,000 under Rule 11, payable to the Clerk within 21 days; required to certify verification of every citation in all subsequent briefing in the case; ordered to serve the sanctions order on her client. The court found her conduct “tantamount to bad faith” and “akin to contempt”, permitting sanction on the court's own motion.
Sources
- https://www.courthousenews.com/attorney-sanctioned-over-ai-filings/
- https://www.courthousenews.com/wp-content/uploads/2026/07/attorney-sanctioned-for-ai-briefings.pdf
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