Williams v. Rashid
The case
Angela Williams, et al. v. Jamal Rashid, et al., U.S. District Court for the District of Nevada, June 9, 2026, Case No. 2:21-cv-01676-APG-MDC, Doc. 415 (Chief Judge Andrew P. Gordon). Note on date: the signature block reads "DATED this 9th day of June, 2025," but the ECF file stamp reads Filed 06/09/26 and the order's internal deadlines run in June and July 2026, so the order is treated as dated June 9, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-68-williams-v-rashid.pdf`.
What happened
Jane Doe #2's counsel filed a motion for reconsideration containing AI hallucinations; local counsel Jason Guinasso admitted using AI, which produced the hallucinations, while NCOSE attorneys Victoria Hirsch and Christen Price said they had not known about the AI use. Counsel then filed two errata, an amended motion, and an amended reply that still contained AI hallucinations, all without leave of court, and never withdrew the offending filings despite acknowledging that hallucinations remained.
The rule and the sanction
Sanctions under 28 U.S.C. section 1927 and the court's inherent authority. The court denied the reconsideration motion (ECF No. 326) with prejudice, struck ECF Nos. 336 through 339, granted defendant Las Vegas Bistro's motion to strike and for sanctions in part, and awarded Bistro its reasonable AI-related fees and costs for responding to the original reconsideration motion and attending the hearing, imposed jointly and severally against the National Center on Sexual Exploitation and Guinasso Law, Ltd., to be conferred by June 26, 2026, or pursued by motion under Local Rule 54-14 by July 14, 2026. The row's metadata dated this matter June 9, 2025 and listed a $1 placeholder penalty; the document corrects both points. Source URL: the primary PDF (Charlotin documents archive: /documents/2389/Williams_v._Rashid_USA_10_June_2026.pdf, https://www.damiencharlotin.com/documents/2389/Williams_v._Rashid_USA_10_June_2026.pdf).
How it could have been avoided
Withdraw or correct filings as soon as AI errors are identified; re-filing corrected versions that still contain hallucinations compounds the violation. Local and co-counsel must communicate about AI use in shared filings. Read opposing counsel's briefs, which often flag errors first.