A Third Court Addresses AI Privilege and Protective Order Issues

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Why it matters

A third U.S. federal court, the District of Colorado, ruled on March 30, 2026, in Morgan v. V2X, Inc. that AI-assisted litigation materials created by a pro se plaintiff using public AI tools qualify as protected work product under Federal Rule of Civil Procedure 26(b)(3), rejecting automatic waiver of protection.[1][3][5] The court compelled disclosure of the specific AI tool names to allow the defendant to check for confidential information breaches but amended the protective order to bar uploading confidential data into mainstream public AI tools (e.g., ChatGPT, Claude, Gemini) without contractual safeguards matching the order's requirements, including deletion rights and documentation retention.[1][3][5]

Involved parties include pro se plaintiff Morgan, defendant V2X, Inc. (an employer in this discrimination/wrongful termination case), and presiding judge in the U.S. District Court for the District of Colorado.[1][3][5] This follows two prior rulings: U.S. v. Heppner (S.D.N.Y., Feb. 10/17, 2026, by Judge Jed S. Rakoff), denying privilege/work product protection for a criminal defendant's unsupervised use of public AI (Claude) due to lack of confidentiality and attorney involvement,[2][4][6][7][8] and an unspecified second case contributing to the "third court" tally.[1][3]

The dispute arose when V2X refused to produce its insurance policy without AI tool disclosure and usage limits, citing confidentiality risks under the existing protective order; both sides used AI, but the pro se plaintiff lacked defendant's proprietary system, prompting "technological gap" arguments.[5] This builds on Heppner's emphasis on technology-neutral privilege principles, where public AI inputs lack confidentiality assurances.[2][6]

**Newsworthy as the latest in rapid 2026 judicial evolution addressing AI's litigation role—post-Heppner's high-profile "first impression" denial—offering pro se/protected use affirmation while imposing practical disclosure and confidentiality curbs amid widespread lawyer/client AI adoption.[1][3][5][2]

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