LeDoux v. Outliers, Inc.
The case
LeDoux v. Outliers, Inc., W.D. Wash.: sanctions order July 24, 2026 (2026 WL 2137370); expert-exclusion order August 18, 2026 (2026 WL 2408808); earlier exclusion January 9, 2026 (2026 WL 76377 at *11 n.6). Reported at: https://nwsidebar.wsba.org/2026/08/31/federal-court-excludes-expert-for-ai-hallucinated-citations/
What happened
Plaintiff's counsel filed at least five filings containing "dozens of inaccurate factual and legal citations." She also participated in preparing expert reports: one expert's report contained AI-generated "hallucinated" citations to academic articles, and an earlier excluded expert's report had similar problems. The lawyer conceded her role and admitted the inaccurate citations were generated by two AI tools that she claimed she did not understand how to use, and that the experts themselves had not verified the material.
The rule and the sanction
The July 24, 2026 order imposed a $3,000 sanction, required per-brief certification, and directed that a copy of the order be provided to the client; counsel had filed a further defective filing after notice (the Cap 2 predicate for the R5 grade). The August 2026 order excluded the expert whose report rested on hallucinated academic citations.
How it could have been avoided
Supervision duties extend to materials you help experts prepare: verify every citation in an expert report, including citations to academic literature, before the report is served. Do not deploy AI tools you "do not understand how to use" on client matters, obtain training first. Confirm with retained experts that they have independently verified their sources.