Yue v. Reaction Labs, LLC
U.S. District Court, Western District of Texas, Austin Division · W.D. Tex. · Texas bar guidance
Verified April 26, 2026
- Citation
- Yue v. Reaction Labs, LLC, No. 1:24-CV-1125-RP, 2026 WL 157144 (W.D. Tex. Jan. 20, 2026)
- Decided
- January 20, 2026
Summary
Counsel for counter-plaintiff Reaction Labs LLC (a/k/a Lup), Daniel Scardino of Scardino LLP and Henning Schmidt of Stradling Yocca Carlson & Rauth LLP, filed a response brief opposing a motion to vacate a preliminary injunction that contained two defective case citations. The brief cited Cummins-Allison Corp. v. SBM Co., 2009 WL 763926, at *10, but the cited order is only eight pages long, making a pin cite to page *10 impossible. The brief also cited Fiber Sys. Int'l v. Applied Optical Sys., 2009 WL 8590962, at *8-9, with the wrong publication month and to a pin cite past the order's six-page length. Judge Robert Pitman flagged the errors in footnote 10 of the order.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. Judge Pitman cautioned Lup's counsel "to cite-check his filings in the future, as such mistakes may suggest reliance upon artificial intelligence without independently validating the accuracy of generated citations." The court separately rebuked Lup for "blatantly misrepresenting" the holding of DUSA Pharmaceuticals in the same brief, and granted the motion to vacate the preliminary injunction.
Why does Yue v. Reaction Labs, LLC matter for law firms using AI?
Yue v. Reaction Labs illustrates a softer but still public form of judicial accountability: a federal judge identifying probable AI-generated citations in a brief without imposing monetary sanctions, but doing so in a published opinion that names the firms involved. For a managing partner, the takeaway is that the reputational cost of an AI-citation incident does not require a Rule 11 motion. A footnote in a Westlaw-indexed order, paired with a separate finding that the same brief misrepresented controlling case law, is enough to surface the lapse to every future opposing counsel running a conflicts or background check on the firm.
Sources
Primary sources
Further reading
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.