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Georgia Court Won’t Exclude Expert Who Used AI Tools - Seeuwen v. Target Corporation

Georgia Court Won’t Exclude Expert Who Used AI Tools - Seeuwen v. Target Corporation

By Akash Arun
5 min read
Georgia Court Won’t Exclude Expert Who Used AI Tools - Seeuwen v. Target Corporation

Seeuwen v. Target Corporation

State Court of Gwinnett County, Georgia · Civil Action File No. 24-C-05776-S6 · Order on Motion to Exclude Expert Opinion Testimony · Hon. Veronica Cope · Dated July 2, 2026 (e-filed July 8, 2026)

Case Facts

The order comes from a slip-and-fall case, Sasha Seeuwen v. Target Corporation, pending in the State Court of Gwinnett County, Georgia, Civil Action File No. 24-C-05776-S6. Seeuwen claims she was injured in a fall at a Target store on August 2, 2022. Nearly three years later, on April 29, 2025, she was evaluated by Bernard Drexinger, Jr., M.D., a neurologist, who diagnosed her with a condition called Piriformis Syndrome. Seeuwen contends the fall caused the condition and that it has produced ongoing pain and related life difficulties. Target moved to exclude the testimony Dr. Drexinger proposed to offer supporting that claim, arguing it was unreliable and would not help a jury. Judge Veronica Cope decided the motion without oral argument, as permitted under Uniform Superior Court Rule 6.3, applying Georgia’s expert-witness statute, O.C.G.A. § 24-7-702(b).

The Setup

Target’s motion raised three objections to Dr. Drexinger’s proposed testimony: that it failed to establish, to a reasonable degree of medical certainty, that the fall caused Seeuwen’s Piriformis Syndrome; that his diagnostic process was cursory and occurred well after the fall; and - the AI-related objection - that Dr. Drexinger overrelied on “Google AI Search results and other AI programs such as ChatGPT.” At his deposition, Dr. Drexinger admitted using AI tools both in preparing for the deposition itself and in preliminary research during his normal medical practice.

The Challenge

The order treats the AI issue as one part of a broader reliability challenge rather than a standalone basis for exclusion. The court found Dr. Drexinger “manifestly qualified” to testify about neurological ailments including Piriformis Syndrome, and noted that he based his causation opinion on the “[m]echanism of injury” and on ruling out other lifestyle factors. On the AI question specifically, the court wrote that it “understands Defendant’s concern regarding Dr. Drexinger’s admitted use of AI tools in, apparently, preparing for his deposition, as well as in preliminary research during the normal course of his medical practice,” but concluded that “the use of AI tools for basic preliminary research tasks or in preparing for deposition does not render his testimony inadmissible.”

The Ruling

Judge Cope denied the motion to exclude Dr. Drexinger’s testimony in its entirety. She wrote that the timing gap between the fall and the diagnosis, and Target’s criticism that Drexinger applied “insufficient rigor to ruling out other potential causes,” were arguments the jury “may be persuaded by,” but that they “cannot provide a basis for wholesale exclusion of the proposed testimony.” She reached the same conclusion on the AI issue, holding that a jury “may find Dr. Drexinger’s use of such tools relevant in determining his credibility at trial,” while the AI use itself was not a ground for exclusion. The order concludes: “ORDERED, that the motion to exclude testimony of Bernard Drexinger, Jr., M.D. is DENIED.”

The Kicker

Of the three objections Target raised, the one aimed squarely at artificial intelligence got the shortest treatment - folded into a single paragraph that handled ChatGPT and Google AI Search the same way it handled an unusually long gap between injury and diagnosis: material for cross-examination, not a reason to keep an expert off the stand.

What Was Alleged vs. What the Court Found

→  Alleged: Dr. Drexinger overrelied on Google AI Search results and other AI programs such as ChatGPT, undermining the reliability of his causation opinion.

→  Admitted: at deposition, Drexinger acknowledged using AI tools both to prepare for that deposition and for preliminary research in his ordinary medical practice.

→  Found: that use, without more, does not render his testimony inadmissible; it may affect how a jury weighs his credibility at trial.

→  Ruling: the motion to exclude Drexinger’s testimony is denied in full, on the AI ground and on the two other reliability objections Target raised.

The Lesson

The order treats an expert’s admitted AI use as a credibility question for the jury rather than a threshold admissibility problem, so long as that use was confined to preliminary research and deposition preparation rather than the substance of the opinion itself. That line - between AI as a research aid and AI as the source of the opinion’s content - did more work in this ruling than the fact that AI was involved at all.

Takeaways

If you’re retaining experts:

Document what any AI tool was actually used for. This order turned on the fact that Drexinger’s AI use was preliminary research and deposition preparation, not the basis of his diagnosis or causation opinion.

If you’re an expert:

Be ready to explain the boundary between what you researched with an AI tool and what your opinion actually rests on - that boundary was the deciding fact here, not the mere admission of using AI.

If you’re opposing counsel:

An admission of AI use alone did not move this court; pair it with a direct challenge to the methodology or timeline behind the opinion, as Target did with its other two objections, rather than relying on the AI angle in isolation.

About the Author

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Akash Arun

VP, Strategic Research @ Exlitem