LeDoux v. Outliers, Inc.

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

The case was dismissed with prejudice on August 18, 2026. The docket shows a later filing on September 9, 2026, whose content was not available for this entry. No appeal was located.

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

• U.S. District Court, W.D. Wash. (via Justia) · July 24, 2026
  Order on Sanctions, Dkt. 265
• U.S. District Court, W.D. Wash. (via Justia) · August 18, 2026
  Order Granting Defendants' Motion for Summary Judgment, Dkt. 269
• U.S. District Court, W.D. Wash. (via Justia) · January 9, 2026
  Order Granting Defendants' Motion for Partial Summary Judgment, Dkt. 202
• NWSidebar (Washington State Bar Association) · August 31, 2026
  Federal Court Excludes Expert for AI 'Hallucinated' Citations

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 September 9, 2026 docket entry and any appeal were not located.