Kabir v. WebMD LLC

What sanction did the court impose?

Memorandum Order entered February 3, 2026 (ECF No. 192) revoking pro se plaintiff's ADS filing privileges and denying his motions at ECF Nos. 158 and 165 with prejudice. The earlier December 2, 2025 Text Order (ECF No. 117) issued an explicit warning that further hallucinated citations may result in sanctions and conditioned acceptance of oppositions on compliance with page limits and citation accuracy. The court has not, on the record retrieved here, imposed monetary sanctions or referred the matter to bar authorities; the February 3 order is a filing-privileges sanction.

Why does Kabir v. WebMD LLC matter for law firms using AI?

Kabir v. WebMD is a pro se patent and trade-secret action filed by Azad Alamgir Kabir in the District of New Jersey. Judge Evelyn Padin’s December 2, 2025 Text Order (ECF No. 117) is the first AI-citation moment in the docket. The order denies plaintiff’s request to file overlength briefs and flags a citation in plaintiff’s papers to “United States v. Schiff, No. 17-7306, 2020 WL 1234567 (D.N.J. Mar. 12, 2020).” The court explains that the cited Westlaw identifier exists for no case and the case number corresponds to a different matter (Vandium LLC v. Datamotion, Inc.). The order warns: “Hallucinated citations will not be excused, and the Court may sanction Plaintiff for further uses of hallucinated citations.” It also references the court’s Judicial Preferences, which include guidelines on the use of generative artificial intelligence.

Plaintiff had separately filed a Notice Regarding Use of Cognitive Artificial Intelligence on September 6, 2025 (ECF No. 58). After multiple subsequent filings via the District’s Alternate Document Submission (ADS) channel that the Clerk’s Office rejected for technical or formatting reasons, Judge Padin entered a Memorandum Order on February 3, 2026 (ECF No. 192) revoking plaintiff’s ADS filing privileges and denying with prejudice his motions at ECF Nos. 158 and 165 (a Rule 59/reconsideration cluster). The order is captioned a Preclusion Order on the docket. Whether the order’s primary basis is the December 2 hallucination warning or broader noncompliance is not directly verifiable: the public PDF on RECAP is a scanned image without embedded text, and the order’s reasoning is not summarized on CourtListener beyond the one-line docket entry.

For firms litigating against pro se plaintiffs in the District of New Jersey, Kabir is a useful sequence to cite when escalating from a hallucination warning to a privileges sanction. The pattern (initial warning, continued noncompliance, formal restriction on filing channels) is a template the court has now applied. The case also shows how readily a fabricated citation can be detected: the Westlaw identifier “2020 WL 1234567” is on its face implausible, and a thirty-second cross-check against the underlying case number was sufficient to expose the error.