Euphoric, LLC v. Westport Community Improvement District

What is the current procedural posture?

The court denied The Sourze's motion to file the corrected brief as moot and ordered Brown to show cause why she should not be sanctioned under Rule 11, 28 U.S.C. 1927, and the court's inherent authority. Her response had to include a declaration explaining how she researched and drafted the two filings, what she did to validate the citations, what she did differently from her earlier briefing, and what procedures will prevent inaccurate citations in future filings, plus a brief of up to 15 pages, due July 8, 2026. The court said the deficiencies "directly implicate counsel's duty of candor to the Court." In a footnote it noted that UNIKC's counsel, Stephen Williams, had signed some of the earlier deficient briefs, directed the order only to Brown as the signer of the two filings, and said nothing in it forecloses other action on earlier or future briefs. The docket shows Brown's response filed July 9, 2026 (ECF No. 527) and no ruling on it through September 24, 2026.

Why does Euphoric, LLC v. Westport Community Improvement District matter for law firms using AI?

This matter shows a court escalating in stages. In its June 3, 2026 ruling on the defendants’ motions to dismiss, the court flagged in a long footnote that “a number of citations in Plaintiffs’ briefs are incorrect and somewhat inaccurate or misleading in substance,” set out representative examples, and stated that it did “not presume that the erroneous citations and assertions in Plaintiffs’ briefing were submitted or made in bad faith or with any ill intent by counsel.” It then reminded counsel that “whatever the root cause for these inaccuracies and errors (including any use of legal or non-legal generative AI tools, for example),” attention to the form and substance of legal authority is a duty of counsel as officers of the court.

The June 22 order took up two more filings. The Sourze’s opposition to a motion to exclude an expert attributed quotations to Bonin and Watson that do not appear in those cases; the court could find no case containing the Watson language, or one containing both Bonin passages together. The Sourze’s motion to amend described the errors as “inadvertent” and the result of “drafting errors” and said the corrected brief would use “correct, verified citations.” The court found the proposed corrected brief cited “Rodriguez v. United States, 823 F.3d 593,” which “does not appear to reference an actual case,” attributed quotations from one Missouri case to another, and cited several decisions for propositions they did not support. The court called it “inexplicable” that the corrected filing “contains more of the same.”

The show-cause order is directed only to the signing attorney, and it asks for process, not just an apology: how she researched and drafted the filings, how she validated each citation, what she did differently after notice, and what procedures will apply going forward. As of the last docket entry read, her response was on file and the court had not ruled. Firms documenting compliance may wish to consider that, in this case, the court treated a firm’s correction of flagged citations as a filing that itself had to be verified, and measured the new errors against the notice already given.