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LeDoux v. Outliers, Inc.

Plaintiff's counsel used an AI system to generate a citation table and gave it to two experts, who attached it to their reports. The court personally sanctioned counsel $3,000 and later excluded a third expert whose report contained fabricated citations.

Primary document readCounsel sanctioned $3,000; third expert excluded; case dismissed July 24, 2026

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What happened

Joann LeDoux sued the maker of a nootropic dietary supplement in federal court in Tacoma. In November and December 2025, filings on her behalf contained, in the court's words, "dozens of inaccurate factual and legal citations which appeared 'hallucinated' by a generative artificial intelligence tool."

Responding to the defendants' sanctions motion, plaintiff's counsel Jocelyn Stewart said she had used Claude or ChatGPT to "generate a formatted citation table" for academic articles. She said she "provided the same AI-generated citation table to both experts as an appendix, and neither expert caught the errors in the citation data before signing their reports." The two experts who received the table were James Kababick and Dr. Ronald Shippee.

A third plaintiff's expert, Dr. Gabriel Holguin, submitted a report that also contained citations the defendants showed were fabricated. Counsel was not asked to explain those citations, and the court did not find who generated them.

What the court did

On January 9, 2026, Judge Tiffany M. Cartwright struck Dr. Shippee's report, Mr. Kababick's second report, and two other experts' evidence because they had been disclosed after the deadline (Dkt. 202). The citation table was not the ground for that ruling.

On July 24, 2026, the court ruled on sanctions under Rule 11 (Dkt. 265). It noted that it had "already struck these expert opinions for other reasons" and treated the tainted reports as further evidence of bad faith. The order states: "Attorney Jocelyn Stewart is personally sanctioned in the amount of $3,000." It also required her to certify that every citation in future briefing had been verified and to give a copy of the order to her client.

On August 18, 2026, the court granted the defendants' motion to exclude Dr. Holguin, finding that his "multiple hallucinated citations 'shatter[] his credibility with this Court,'" a phrase taken from Kohls v. Ellison. It then granted summary judgment and dismissed the plaintiff's remaining claims with prejudice (Dkt. 269).

Where it stands

Three separate rulings make up this matter, and they are easily run together.

At Dkt. 202, on January 9, 2026, the court struck the expert evidence of Drs. Dezell, Okano and Shippee, along with Mr. Kababick's second report, under Federal Rule of Civil Procedure 37(c)(1), a disclosure sanction. Plaintiff's motion for lesser sanctions and reconsideration of that ruling was denied at Dkt. 262 on July 8, 2026.

At Dkt. 265, on July 24, 2026, the court personally sanctioned attorney Jocelyn Stewart $3,000 under Rule 11(b), payable to the Clerk within 21 days, and required her to certify citation verification in all future briefing in the case and to give a copy of the order to her client.

At Dkt. 269, on August 18, 2026, the court entered a combined order granting three motions: exclusion of Ms. Evelyn Cadman on grounds unrelated to artificial intelligence, exclusion of Dr. Gabriel Holguin, and summary judgment dismissing the remaining claims with prejudice. Judgment was entered the same day at Dkt. 270. The decision is reported at 2026 WL 2408808.

Post-judgment activity through September 14, 2026 consists of bills of costs and supporting declarations. No notice of appeal appears on the docket. The appeal period under Rule 4(a)(1)(A) would run from the August 18 judgment, so this should be re-checked before the absence of an appeal is treated as final.

The obligation it engaged

This matter illustrates Clause 3, independent authority, from an uncomfortable angle. The defective material did not come from the experts. It came from counsel, and it arrived looking finished. Once it was inside a signed report, it was on the expert's authority whatever its origin. Verifying every citation against the source itself is the check that would have caught it.

It also bears on Clause 4, checkability before adoption. A citation table is easy to check. Each entry names a document that either exists and says what it is cited for, or does not. The experts who adopted the table without that check had the means to catch the errors in hand. Material supplied by counsel is still material the expert adopts.

Sources

What could not be confirmed

Quotations were taken from text extracted from the orders and should be checked against the PDFs character by character. The court did not make its own finding about what the two experts examined; that description is counsel's, as quoted in the sanctions order. The docket was last observed on September 14, 2026 and the appeal period from the August 18, 2026 judgment had not clearly closed; the absence of a notice of appeal should be re-verified.

About this entry

This entry was checked against the primary document listed in the sources. The entry for LeDoux v. Outliers, Inc. records conduct and what the tribunal did. It does not characterize a holding and it is not legal advice. Last checked September 17, 2026. More matters like this one are collected under expert witnesses and AI. If something here is out of date, write to [email protected].

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