LeDoux v. Outliers, Inc.
U.S. District Court, Western District of Washington · W.D. Wash. · Washington bar guidance
Verified May 5, 2026
- Citation
- LeDoux v. Outliers, Inc., No. 3:24-cv-05808-TMC, 2026 WL 291023 (W.D. Wash. Feb. 4, 2026)
- Filing date
- February 4, 2026
Summary
Judge Tiffany M. Cartwright ordered plaintiff's counsel to show cause why Rule 11 sanctions and disciplinary referral should not issue after finding dozens of inaccurate factual and legal citations across at least five filings. Among the defective authorities was a fabricated Washington Supreme Court citation, Berg v. Chevrolet Motor Div., 84 Wn.2d 102, that does not exist. The order noted that subsequent "corrections" by counsel introduced false quotations and altered the meaning of cited authority rather than acknowledging the underlying material was unsupported.
- AI tool:
- Unspecified generative AI
What is the current procedural posture?
Pending as of 2026-05-01. The February 4, 2026 Order to Show Cause was the most recent sanctions-related action; counsel filed a response and commentary published 2026-04-06 noted "It remains to be seen what sanctions, if any, the court will impose." No final sanctions order has issued. When decided, the ruling will define what Rule 11(b) reasonable inquiry requires of W.D. Wash. attorneys using a generative AI tool, in a district that has no AI standing order.
Why does LeDoux v. Outliers, Inc. matter for law firms using AI?
LeDoux is the volume case in the AI-hallucination canon: the problem was not a single fabricated citation but dozens of defective authorities spread across five filings, with “corrections” that compounded rather than cured the underlying Rule 11 problem. For a managing partner, the lesson is that an OSC posture can survive even diligent-looking remediation if the remediation itself is built on the same un-verified workflow that produced the original errors.
Sources
Primary sources
Further reading
- Justia (legal aggregator)
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- Plaintiff's counsel's individual name (the Charlotin PDF was unreadable to the verification toolchain; counsel of record per public docket coverage is associated with the plaintiff's filings, but the order's specific naming of the sanctioned attorney was not directly confirmed in this pass).
- Whether any AI tool was named expressly in the order; aggregator coverage and the candidate row treat the AI source as implied rather than identified.
- Final disposition is pending; the show-cause response is on the docket but the court has not issued a sanctions order. Update this entry within one week of the court's eventual ruling.