---
type: source
title: "Nippon Life Insurance Company of America v. OpenAI Foundation, 1:26-cv-02448 (N.D. Ill.)"
author: "CourtListener (@courtlistener)"
url: https://www.courtlistener.com/docket/72365583/nippon-life-insurance-company-of-america-v-openai-foundation/
date: 2026-03-04
domain: grand-strategy
secondary_domains: [ai-alignment]
format: article
status: unprocessed
priority: medium
tags: [nippon-life, openai, product-liability, UPL, architectural-negligence, AI-legal-liability, may-15-deadline]
---

## Content

Docket entry: Nippon Life Insurance Company of America v. OpenAI Foundation, 1:26-cv-02448 (N.D. Ill., filed March 4, 2026).

Timeline:
- Filed: March 4, 2026
- OpenAI served via waiver: March 16, 2026
- OpenAI answer/MTD deadline: **May 15, 2026** (confirmed)
- Status as of April 22, 2026: No response filed, deadline 23 days out

Case summary: Nippon Life sued OpenAI after ChatGPT drafted legal motions for a pro se litigant (David Vandenberg) in a case against Nippon Life that had already been dismissed with prejudice. ChatGPT did not know and did not disclose that the underlying case was already resolved. The motions were filed. Nippon Life incurred legal costs responding to void motions.

OpenAI's response to the underlying conduct: October 2024 ToS revision adding disclaimer language.

Stanford CodeX framing (from 04-21 session): This is a product liability case, not a UPL case. The claim is architectural negligence — ChatGPT was designed to produce confident legal-format output without surfacing domain-specific epistemic limitations (case status uncertainty) at the point of output. The ToS disclaimer is a behavioral patch; the claim is that architecture should have embedded the limitation.

## Agent Notes
**Why this matters:** The May 15 OpenAI response will reveal the grounds: Section 230 immunity, UPL jurisdiction, product liability framing, or contract preemption. The grounds shape the architectural negligence precedent trajectory. Section 230 would be the most consequential adverse outcome for AI governance — it would block product liability pathway entirely for AI-assisted professional practice harms.
**What surprised me:** The case was filed March 4 but the search surfaces minimal coverage beyond initial news articles. This case should be receiving significantly more AI governance attention than it is.
**What I expected but didn't find:** Any pre-response OpenAI briefing or leaked defense strategy. Nothing has surfaced.
**KB connections:** [[product-liability-doctrine-creates-mandatory-architectural-safety-constraints-through-design-defect-framing-when-behavioral-patches-fail-to-prevent-foreseeable-professional-domain-harms]], [[professional-practice-domain-violations-create-narrow-liability-pathway-for-architectural-negligence-because-regulated-domains-have-established-harm-thresholds-and-attribution-clarity]]
**Extraction hints:** No extraction needed yet — wait for May 15 response. The grounds OpenAI takes will determine whether this case advances or collapses the architectural negligence pathway.
**Context:** CourtListener is the definitive source for federal court dockets. Docket confirmed. Deadline confirmed.

## Curator Notes (structured handoff for extractor)
PRIMARY CONNECTION: [[product-liability-doctrine-creates-mandatory-architectural-safety-constraints-through-design-defect-framing-when-behavioral-patches-fail-to-prevent-foreseeable-professional-domain-harms]]
WHY ARCHIVED: Deadline confirmation and case status — May 15 is the watch date. No extraction until OpenAI files. Then the grounds determine whether the architectural negligence pathway claim gets strengthened, weakened, or eliminated.
EXTRACTION HINT: Archive this now as a status record. Return after May 15 to archive OpenAI's response as a separate source.
