US District Court, Western District of Washington (Judge Tiffany M. Cartwright), case 3:24-cv-05808-TMC. Report author: James Kababick, retained testifying expert for the plaintiff.
LeDoux v. Outliers, Inc., 2026 WL 2408808 (W.D. Wash. 18 Aug 2026) (unpublished)
Withdrawn · 18 August 2026
What was fabricated
Hallucinated citations to ACADEMIC ARTICLES inside a retained expert's report, together with citation errors identical to those in a second expert's report. ⚠️ UNUSUAL FOR THIS REGISTER AND THE REASON THE ROW EXISTS: the register's Legal rows are overwhelmingly fabricated LEGAL AUTHORITIES in filings by counsel. Here the fabricated material is SCIENTIFIC LITERATURE, inside an expert's own report, in a product-liability matter about nootropic supplements. 🔴 THE DOCUMENT IS THE EXPERT'S; THE FABRICATION IS COUNSEL'S. Counsel generated the citation table and supplied it to both testifying experts as an appendix, and on her own later account prepared the expert reports; the expert signed without verifying. The court's 4 February 2026 order records that a second expert's report "cites the same articles and includes the same citation errors".
What happened as a result
The court excluded the expert's report, holding the fabricated citations rendered the opinions unreliable under Federal Rule of Evidence 702 and that they "shatter … his credibility with this Court". With the evidence excluded the plaintiff could not withstand summary judgment and the claims were dismissed WITH PREJUDICE. ⚠️ SEPARATE AND EARLIER, AND NOT THIS ROW: on 9 January 2026 the same judge STRUCK expert evidence under Rule 37(c)(1) — a DISCOVERY sanction, not a fabrication one — and granted partial summary judgment on the amphetamine-adulteration claims. That order expressly DEFERRED the AI question: "The Court will address these arguments in a separate order." The 18 August order is that separate order.
Sources
- https://nwsidebar.wsba.org/2026/08/31/federal-court-excludes-expert-for-ai-hallucinated-citations/
- https://cases.justia.com/federal/district-courts/washington/wawdce/3:2024cv05808/339711/202/0.pdf
- https://cases.justia.com/federal/district-courts/washington/wawdce/3:2024cv05808/339711/209/0.pdf
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