Source: eDiscovery Today

In White v. Walmart, Inc., No. 1:25-cv-01120-RLY-TAB (S.D. Ind. Apr. 14, 2026), Indiana Magistrate Judge Tim A. Baker found that while artificial intelligence can be a useful discovery tool, it is not a substitute for attorneys exercising independent judgment and oversight. The court concluded Plaintiff’s discovery objections were not the product of independent legal analysis because Plaintiff’s counsel had uploaded Defendant’s discovery responses into an AI program, asked AI to identify insufficient responses, and then copied and pasted the AI-generated results into an email to opposing counsel and the Court. Judge Baker ordered Plaintiff to supplement her discovery responses by April 27, 2026.

The ruling recounts procedural facts: Defendant served discovery in July 2025 and disputes that Plaintiff’s August responses were complete; Plaintiff’s original counsel withdrew and new counsel entered but deficiencies persisted. The judge found counsel failed to meet-and-confer in good faith, noting Defendant proposed a March 23, 2026 conference call which Plaintiff’s counsel declined after confirming availability. Judge Baker identified concrete deficiencies—no signed interrogatory responses and no identification of medical providers—and reiterated parties must vet AI outputs and apply human discretion before presenting discovery disputes to the court.