Tlingit Haida Tribal Business Corporation v. OnePromom, LLC

What is the current procedural posture?

The court granted the partial motion to dismiss in part and denied it in part, dismissing Claims One and Seven without prejudice and keeping the civil theft claim. It ordered that, no later than June 23, 2026, "Marianna McLean SHALL SHOW CAUSE, in writing, (1) why the inclusion of an inaccurate quotation in the Motion to Dismiss does not amount to a violation of Rule 11(b) of the Federal Rules of Civil Procedure, and (2) why she should not be sanctioned under Rule 11 and/or the Court's inherent authority under 28 U.S.C. § 1927." No sanction was imposed in this order. The order pairs "inherent authority" with a statutory citation, 28 U.S.C. § 1927; the entry quotes it as printed. As of 2026-09-30 no ruling on the show-cause order has been located: GovInfo holds only this order, and later docket entries through August 2026 (minute orders, memoranda, and ECF Nos. 55 through 71) could not be read, so whether the show-cause was resolved is unknown.

Why does Tlingit Haida Tribal Business Corporation v. OnePromom, LLC matter for law firms using AI?

Tlingit Haida Tribal Business Corporation v. OnePromom is a show-cause order over a single quotation, and its focus is the attorney’s certification rather than the tool. Defense counsel disclosed in the motion itself that “generative artificial intelligence—specifically, Eve Legal—was used to draft this filing,” that the clients consented, and that “[a]ll cited authority was manually reviewed by counsel of record.” The motion then attributed to Seale v. Peacock a sentence that, in Judge Wang’s words, “does not appear in Seale or any other case” and that “overstates the holding in Seale by suggesting the existence of a per se rule.”

The court was candid that the substantive gap was small: the quotation “is not substantially different from the actual language contained in Seale.” It nonetheless treated the misattribution as “a misrepresentation to the Court—and a troubling one,” tying its concern to the certification: “This Court is concerned that counsel attributed an inaccurate quotation to Seale despite certifying that she ‘manually reviewed’ all cited authority.” It cited the Tenth Circuit’s statement in Amarsingh v. Frontier Airlines that attorneys have a “fundamental duty” to ensure they are “accurately quoting from the cited authorities,” and Park v. Kim on the Rule 11 duty to read and confirm the authorities relied on.

The order directs Marianna McLean to show cause in writing why the inaccurate quotation is not a Rule 11(b) violation and why she should not be sanctioned; its outcome could not be confirmed from the public record as of September 30, 2026. Firms documenting compliance may wish to consider that an AI-use certification can raise the stakes of an ordinary citation error: a statement that every authority was manually reviewed becomes a representation the court can measure the brief against.