N-Bar Trade, Inc. v. Amazon.com Services LLC
U.S. District Court, District of Columbia · D.D.C. · District of Columbia bar guidance
Verified April 26, 2026
- Citation
- N-Bar Trade, Inc. v. Amazon.com Servs. LLC, No. 25-cv-918 (RC), 2025 WL 2986447 (D.D.C. Oct. 22, 2025) (Contreras, J.)
- Decided
- October 22, 2025
Summary
In an opinion granting Amazon's motion to compel arbitration, Judge Rudolph Contreras flagged that plaintiffs' counsel Kamal Nawash "may have relied on artificial intelligence" to draft Mohammed's Opposition, which contained quotations that did not appear in the cases to which they were attributed. Amazon's reply brief identified several quotations it could not locate in the cited authorities. Because the case was being dismissed without prejudice and referred to arbitration, the court declined to impose sanctions, but warned Mr. Nawash on the record about Rule 11(b)(2) and D.C. Rule of Professional Conduct 3.3(a)(1).
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction or formal discipline. The court issued an on-the-record warning and a conditional show-cause threat: "if this case somehow returns to this Court, Mr. Nawash will be required to show cause why he ought not be sanctioned for his use of nonexistent quotations in his filing." Underlying motion to compel arbitration granted; case dismissed without prejudice.
Why does N-Bar Trade, Inc. v. Amazon.com Services LLC matter for law firms using AI?
N-Bar illustrates the warning-only end of the AI-hallucination spectrum: the court identified fabricated quotations in opposing counsel’s brief, named the attorney by name in a published opinion, and left a show-cause threat hanging over any return to federal court, but imposed no monetary sanction because the case itself was being sent to arbitration. For a managing partner, the operative risk is reputational and conditional, not financial. The opinion is now a citable Westlaw decision (2025 WL 2986447) flagging the lawyer by name, and a future filing in any forum that triggers a Rule 11 inquiry inherits this record.
Sources
Further reading
- CourtListener docket search (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.
- CourtListener docket page for Civil Action No. 25-918 (RC) was not directly retrieved during verification; Westlaw cite 2025 WL 2986447 confirmed from the slip opinion header.