Essandoh v. Capital One Bank NA (Apr. 16, 2026)

Case details
Full caption
Laud Essandoh v. Capital One Bank NA
Country
United States
Jurisdiction
Federal
Decided
Apr. 16, 2026
Disposition
Dismissed
Majority
Bill Davis United States (J.) (unanimous Court)
LAUD ESSANDOH v. CAPITAL ONE BANK NA, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 1040383Only the Westlaw citation is currently available.United States District Court, E.D. Texas, Sherman Division.LAUD ESSANDOHv.CAPITAL ONE BANK NANO. 4:25-CV-00746-ALM-BD|Filed 04/16/2026Attorneys and Law FirmsDagim Melka, Dallas, TX, Pro Se.ORDER ON DISCLOSURE ANDCERTIFICATION REQUIREMENTS FOR USEOF GENERATIVE ARTIFICIAL INTELLIGENCEBill Davis United States Magistrate Judge*1 Today, the court held a discovery hearing based onthe parties' joint report, Dkt. 25, following the court'sface-to-face order, Dkt. 24. Minute Entry for Apr. 16,2026. At the hearing, the court questioned plaintiff LaudEssandoh regarding inaccuracies in his part of the joint report.Id. Essandoh admitted that the inaccuracies resulted fromreliance on generative artificial intelligence (“AI”). Id. Thecourt admonished him about the risks of that misplacedreliance and the sanctions that can result from it. Id. This ordersupplements what the court said at today's hearing.Although AI can be a helpful tool, it can—and often does—generate flawed, or even fake, content. And when anonexistent or inaccurate citation appears in a court filing,[t]he opposing party wastes time andmoney in exposing the deception.The Court's time is taken from otherimportant endeavors. The client maybe deprived of arguments based onauthentic judicial precedents. There ispotential harm to the reputation ofjudges and courts whose names arefalsely invoked as authors of the bogusopinions and to the reputation of aparty attributed with fictional conduct.It promotes cynicism about the legalprofession and the American judicialsystem. And a future litigant may betempted to defy a judicial ruling bydisingenuously claiming doubt aboutits authenticity.Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448–49 (S.D.N.Y.2023).This court's rules provide warnings and guidance about theuse of AI. Loc. R. AT-3(m), CV-11(g). All attorneys and prose litigants who file documents here are bound by those rulesand this order, which supplements the rules in the followingthree ways:1) CertificationConsistent with Federal Rule of Civil Procedure 11(b), anydocument filed in this court that was prepared with theassistance of AI must include a “Certificate of GenerativeArtificial Intelligence Usage” that: (1) discloses that AI wasused when preparing the filing; (2) identifies each AI tool thatwas used and explains how it was used; and (3) states thatthe filer has confirmed the accuracy of every part of the filing—including every factual, procedural, or legal assertion orcitation—that was prepared with the assistance of AI.The court will assume that any filing that does not contain thiscertification was prepared without any use of AI.2) ResponsibilityIf AI is used to prepare any filing, the attorney or prose litigant who signs it will be held responsible for thecontent of the filing under Federal Rule of Civil Procedure11 and applicable rules of professional conduct and attorneydiscipline.3) SanctionsIf the court has good cause to believe that an attorney or prose litigant has relied on AI in violation of this order or anyapplicable rule, the court may impose appropriate sanctions,
LAUD ESSANDOH v. CAPITAL ONE BANK NA, Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2including striking a filing, dismissing a claim or defense,dismissing a case, and ordering monetary sanctions.So ORDERED and SIGNED this 16th day of April, 2026.All CitationsSlip Copy, 2026 WL 1040383End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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