Allen v. Amazon
U.S. District Court, Northern District of Texas · N.D. Tex. · Texas bar guidance
Verified May 14, 2026
- Citation
- Allen v. Amazon, No. 3:24-cv-02846-D (N.D. Tex. Dec. 23, 2025) (Fitzwater, J.) (Memorandum Opinion and Order, ECF No. 76)
- Decided
- December 23, 2025
Summary
Samuel Lombeh Allen, proceeding pro se, sued Amazon in the Northern District of Texas. When Amazon moved to strike Allen's discovery motion for failure to disclose his use of AI, Allen did not dispute that he had used a generative AI tool or that he had omitted the disclosure that Northern District of Texas Local Rule 7.2(f)(1) requires on the first page of any AI-drafted brief. Amazon represented that Allen's AI use had produced "non-existent cases and procedures" and "hallucinated quotations"; the court separately noted that Allen had also referenced a standing order that does not exist.
- AI tool:
- Unidentified generative AI (Allen did not dispute using AI; no specific tool named)
What sanction did the court impose?
On the merits, the court denied Allen's motion to compel, granted in part his motion to modify Amazon's third-party subpoenas, and denied his motion for a protective order. The court declined to sanction Allen for the undisclosed AI use, noting he was pro se and had not been warned before. It admonished him instead, and warned that going forward, failure to comply with Local Rule 7.2(f) "may result in the imposition of sanctions, including the striking of filings, the imposition of filing restrictions, monetary penalties, or dismissal of this action."
Why does Allen v. Amazon matter for law firms using AI?
Allen v. Amazon turns on a disclosure rule rather than the fabricated citations themselves. The Northern District of Texas requires, by local rule, that any brief prepared with generative AI say so on its first page. Allen did not make that disclosure, and when Amazon moved to strike his discovery motion over it, Allen did not dispute either the AI use or the missing disclosure.
Judge Fitzwater’s handling is the pattern worth noting for firms with Northern District of Texas matters. The court resolved the underlying discovery motions on their merits, addressed the AI-disclosure failure in a separate section, and declined to sanction a first-time pro se offender, choosing instead to admonish him and spell out the sanctions available next time. The order is a clean citation for the proposition that the district’s AI-disclosure rule has teeth, and that a represented party can move to enforce it against a pro se opponent without a separate Rule 11 motion.