Case D-121 · AI Sanctions Case Tracker

Wanyu Zhang v. National Public Radio, Inc.

U.S. District Court for the District of Columbia, December 18, 2025

The case

Wanyu Zhang v. National Public Radio, Inc., No. 1:25-cv-00699-BAH (D.D.C.), order entered December 18, 2025. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-121-zhang-v-npr.pdf`. Source URL: https://www.damiencharlotin.com/documents/2266/Zhang_v._NPR_USA_18_December_2026.pdf

What happened

Attorney Lev Ivan Gabriel Iwashko relied on Google-generated summaries that he said he did not realize were AI-generated. His opposition contained two fictitious cases and eight grossly mischaracterized authorities. The original opposition had already been struck on November 3, 2025.

The rule and the sanction

Under 28 U.S.C. 1927, the court ordered Iwashko to reimburse NPR's reasonable fees and costs for its initial reply and its response to the court's order to show cause. The amount was unspecified. (The row's "$1" figure is erroneous and is not used here.)

How it could have been avoided

(a) AI-generated summaries from any source, including search engines, must be verified against primary authority before citation. (b) After one filing is struck for fake law, every later filing needs independent citation verification, not the same workflow. (c) Claiming not to know the output was AI-generated does not cure the failure to check.

Sources