{
  "protocolVersion": "1.0",
  "testDate": "2026-10-03",
  "testDateLabel": "October 3, 2026",
  "testTimezone": "America/Chicago",
  "reviewStatus": "pending",
  "legalReviewer": null,
  "lawyerReviewMinutes": null,
  "apiCostUsd": null,
  "source": {
    "citation": "Geller v. Uber Technologies, Inc., 2026 IL 132066",
    "officialUrl": "https://www.illinoiscourts.gov/resources/7283c197-ffad-4825-97eb-033edad67bcd/file",
    "pdf": "/documents/field-tests/geller-2026-il-132066.pdf",
    "text": "/documents/field-tests/geller-source.txt",
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  "image": {
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    "width": 1200,
    "height": 900,
    "mobileUrl": "/images/content/field-test-method-mobile.webp",
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    "alt": "Diagram of one supplied court opinion branching into three AI case briefs, followed by eight source checks and a pending named legal review.",
    "caption": "Method diagram: one supplied opinion, three retained responses, source comparison, then legal review. This illustration is not a model output or evidence from the case."
  },
  "runs": [
    {
      "id": 1,
      "response": "## Citation\n\nGeller v. Uber Technologies, Inc., 2026 IL 132066 (Ill. Sept. 24, 2026). Sheridan appealed as independent administrator of Mark Geller’s estate. (¶¶ 1–3.)\n\n## Material facts\n\nOn April 19, 2022, Mark requested an Uber ride. His driver, Ejaz Rathore, lost control on an expressway; the crash fatally injured both men. Sheridan, Mark’s spouse and estate administrator, sued Uber Technologies, Inc., its subsidiary Rasier, LLC, and Rathore, alleging driver negligence, Uber’s vicarious liability, negligence through res ipsa loquitur, survival claims, and wrongful death claims for Mark’s statutory next of kin. (¶¶ 1, 6.)\n\nMark and Sheridan individually accepted separate Uber agreements. Sheridan’s agreement covered disputes connected to her own use, access, and relationship with Uber, including third-party claims related to her use. It delegated threshold arbitrability questions to an arbitrator and incorporated AAA rules. (¶¶ 8–9, 42–43.)\n\n## Procedural history\n\nUber sought dismissal or, alternatively, a stay and an order compelling arbitration. The circuit court compelled arbitration of survival claims under Mark’s agreement, denied arbitration of wrongful death claims, and stayed those claims pending survival arbitration. The estate then voluntarily dismissed its survival actions. (¶¶ 7, 10.)\n\nUber took an interlocutory appeal. The appellate court found Sheridan’s agreement neither procedurally nor substantively unconscionable and concluded its delegation clause required the arbitrator to decide whether wrongful death claims were arbitrable. It reversed and remanded; the Illinois Supreme Court allowed the estate’s appeal and reviewed the circuit court’s denial de novo. (¶¶ 11, 13–16, 20.)\n\n## Issues\n\nDid Sheridan clearly and unmistakably agree to delegate arbitrability of wrongful death claims arising from Mark’s Uber use? If not, did her agreement require arbitration of the underlying wrongful death dispute? (¶ 29.)\n\n## Holding and reasoning\n\nNo on both questions. The court first had to decide whether the parties consented to delegate this dispute; absent that consent, the court also decided that the wrongful death claims were not subject to arbitration. (¶¶ 29, 70, 72–74.)\n\nSheridan occupied three distinct capacities: individual Uber user, wrongful death beneficiary, and estate personal representative. As representative, she was a nominal plaintiff acting for the spouse and any other next of kin, the true beneficiaries. Wrongful death creates a claim accruing at death for beneficiaries’ losses; survival preserves claims already accrued to the decedent. Wrongful death recoveries are not estate assets subject to restriction through Mark’s arbitration agreement. (¶¶ 24–28.)\n\nDelegation is itself an antecedent arbitration agreement. Courts require clear and unmistakable evidence of consent to delegate arbitrability and resolve disputes over formation before enforcing delegation. Sheridan’s delegation language and AAA incorporation did not establish consent concerning another person’s use: read in context, the agreement repeatedly tied arbitration to her own services and contractual relationship. (¶¶ 35–44.)\n\nFAA section 2 reinforced that contractual connection because the wrongful death dispute arose exclusively from Mark’s separate use. Henry Schein bars a court from rejecting an agreed delegation merely because arbitration seems wholly groundless; it preserves the antecedent judicial inquiry into whether delegation was agreed. The court read New Prime and Coinbase as likewise requiring foundational judicial examination of statutory authority and the parties’ actual agreement. (¶¶ 47–49, 54–60, 62–63.)\n\nFor underlying arbitration, Sheridan did not agree in her beneficiary or representative capacity to arbitrate claims arising from Mark’s use, was a nonsignatory to his agreement, and had no corresponding commitment in her individual agreement. Uber therefore failed to establish consent to arbitrate the wrongful death dispute itself. (¶¶ 73–74.)\n\n## Disposition and limits\n\nThe Supreme Court reversed the appellate judgment, affirmed the circuit court, and remanded. Wrongful death proceedings may resume in circuit court; survival counts remain voluntarily dismissed. The court expressly declined procedural and substantive unconscionability arguments. (¶¶ 74, 76–79.)\n\nThe decision rests on Sheridan’s agreement and these claims’ source. The court acknowledged a fine line between delegation scope and consent, and inconsistent decisions. Wrongful death liability remains for further proceedings. (¶¶ 67, 76.)\n",
      "download": "/documents/field-tests/run-1.txt",
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      "wordCount": 645,
      "startedAt": "2026-10-04T03:59:02Z",
      "completedAt": "2026-10-04T04:01:03Z",
      "summary": "Core distinctions preserved; citation support needs attention"
    },
    {
      "id": 2,
      "response": "## Citation\n\n*Geller v. Uber Technologies, Inc.*, 2026 IL 132066 (Ill. Sept. 24, 2026).\n\n## Material facts\n\nOn April 19, 2022, Mark Geller requested an Uber ride. Driver Ejaz Rathore lost control on an expressway; the resulting crash fatally injured both men. Gloria Sheridan Geller (Sheridan), Mark’s widow and independent estate administrator, sued Rathore and Uber Technologies, Inc., together with its subsidiary Rasier, LLC (collectively, Uber), alleging driver negligence, Uber’s vicarious liability, negligence through res ipsa loquitur, survival claims, and wrongful death claims for Mark’s statutory next of kin. (¶¶ 1, 6.)\n\nMark and Sheridan separately accepted Uber agreements containing arbitration provisions. Sheridan’s agreement covered disputes involving her access, use, or relationship with Uber, including third-party claims related to her use; it also assigned threshold arbitrability questions to an arbitrator. (¶¶ 8–9.) Sheridan appeared in three distinct capacities: individual Uber user, wrongful death beneficiary, and estate representative suing nominally for beneficiaries. (¶¶ 24–25.)\n\n## Procedural history\n\nThe Cook County circuit court compelled arbitration of survival claims under Mark’s agreement, denied arbitration of wrongful death claims under Sheridan’s agreement, and stayed the latter pending survival arbitration. The estate then voluntarily dismissed the survival claims. (¶ 10.)\n\nUber took an interlocutory appeal. The First District reversed, rejecting procedural and substantive unconscionability challenges and holding that Sheridan’s delegation clause required an arbitrator to decide wrongful death arbitrability. The Illinois Supreme Court allowed the estate’s appeal and reviewed the arbitration denial de novo. (¶¶ 11, 15–16, 20.)\n\n## Issues\n\nDid Sheridan clearly and unmistakably agree to delegate arbitrability of wrongful death claims arising from Mark’s Uber use? If delegation failed, did her agreement require arbitration of the underlying wrongful death dispute? The estate also challenged the appellate court’s treatment of beneficiary ownership and unconscionability. (¶¶ 18, 29.)\n\n## Holding and reasoning\n\nBoth arbitration questions were answered negatively: the court must decide arbitrability, and these wrongful death claims are not arbitrable. (¶¶ 29, 70, 72–74.)\n\nWrongful death creates a cause of action accruing at death for beneficiaries’ losses; survival preserves claims already accrued to the decedent for his injuries before death. Wrongful death recovery belongs to beneficiaries, not the decedent’s estate, so Mark’s agreement could constrain survival claims without constraining wrongful death claims. Sheridan’s representative status did not merge these distinct interests or her contractual capacities. (¶¶ 24–28.)\n\nDelegation is itself an antecedent arbitration agreement. Courts must first determine whether parties clearly and unmistakably consented to delegate the particular arbitrability dispute; ordinary contractual consent remains essential. Sheridan’s delegation language and incorporated AAA rules did not overcome contractual language repeatedly tying arbitration to her own Uber use. The wrongful death dispute arose solely from Mark’s use. (¶¶ 35–36, 38–45.)\n\nFAA section 2 reinforced that conclusion by requiring a controversy arising from the relevant contract or transaction; Mark’s distinct use failed that threshold for Sheridan’s agreement. (¶¶ 47–49.) *Henry Schein* prohibits courts from disregarding an established delegation because arbitration appears wholly groundless. This decision instead resolved antecedent consent. *New Prime* preserves judicial examination of FAA authority, and *Coinbase* requires courts first to determine the governing agreement. (¶¶ 52, 54–60, 62–63.)\n\nAfter resolving delegation, the court separately rejected arbitration of the underlying claims. Sheridan did not sign Mark’s agreement, and her own agreement signaled no consent, as beneficiary or representative, to arbitrate wrongful death arising from another person’s use. Uber established neither beneficiary nor estate consent. (¶¶ 72–74.)\n\n## Disposition and limits\n\nThe Supreme Court reversed the appellate judgment, affirmed the circuit court, and remanded. Wrongful death proceedings may resume; survival counts remain voluntarily dismissed. (¶¶ 76–79.) It expressly declined to reach procedural or substantive unconscionability. (¶ 74.) Its holding rests on this agreement and these distinct uses and capacities; the court acknowledged a fine distinction between delegation scope and consent, and inconsistent decisions elsewhere. (¶¶ 67, 76.)\n",
      "download": "/documents/field-tests/run-2.txt",
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      "startedAt": "2026-10-04T03:59:28Z",
      "completedAt": "2026-10-04T04:00:59Z",
      "summary": "Core distinctions preserved; citation support needs attention"
    },
    {
      "id": 3,
      "response": "## Citation\n\n*Geller v. Uber Technologies, Inc.*, 2026 IL 132066, Illinois Supreme Court, opinion filed September 24, 2026 (caption; ¶¶ 1–3).\n\n## Material facts\n\nOn April 19, 2022, Mark Geller requested an Uber ride. Driver Ejaz Rathore lost control on an expressway; the crash fatally injured both men. The complaint alleged Rathore’s negligence and Uber’s vicarious liability, asserting survival and wrongful death claims and negligence through res ipsa loquitur. Defendants included Uber Technologies, Inc., its subsidiary Rasier, LLC, collectively termed Uber, and Rathore (¶¶ 1, 6).\n\nGloria Sheridan Geller, Mark’s spouse, acted as independent administrator and wrongful death beneficiary. These capacities differed from her capacity as an individual Uber user. As personal representative, she was the nominal plaintiff pursuing wrongful death claims for statutory beneficiaries, including herself and any other next of kin (¶¶ 24–25).\n\nMark and Sheridan separately accepted Uber agreements containing arbitration provisions. Sheridan’s agreement addressed her own use, access, and relationship with Uber; third-party claims were covered when related to her use. It also assigned threshold arbitrability questions to an arbitrator and incorporated AAA rules and the FAA (¶¶ 8–9, 42–43).\n\n## Procedural history\n\nThe estate filed its nine-count, third-amended complaint in Cook County on February 21, 2023. Uber moved to dismiss or alternatively stay proceedings and compel arbitration (¶¶ 6–7).\n\nThe circuit court compelled arbitration of survival claims under Mark’s agreement, denied arbitration of wrongful death claims, and initially stayed those claims pending survival arbitration. It then granted the estate’s voluntary dismissal of the survival actions (¶ 10).\n\nUber appealed interlocutorily. The appellate court rejected procedural and substantive unconscionability challenges and held that Sheridan’s delegation clause required an arbitrator to determine whether the wrongful death claims were arbitrable. The Illinois Supreme Court allowed the estate’s appeal and reviewed the circuit court’s denial de novo (¶¶ 11, 15–16, 20).\n\n## Issues\n\nDid Sheridan clearly and unmistakably agree to delegate arbitrability of wrongful death claims arising from Mark’s Uber use? If she did not, did her agreement nevertheless require arbitration of the underlying wrongful death dispute (¶ 29)?\n\n## Holding and reasoning\n\nThe court answered both questions no. Wrongful death creates a claim accruing at death for beneficiaries’ losses; survival preserves claims accruing to the decedent before death. Wrongful death recovery is not an asset of the decedent’s estate subject to limitation through his arbitration agreement. Mark’s agreement therefore did not govern these wrongful death claims (¶¶ 26–29).\n\nDelegation is itself an agreement requiring consent. Courts must first determine whether clear and unmistakable evidence establishes agreement to delegate the particular arbitrability dispute; ordinary contract-formation principles govern that inquiry (¶¶ 35–41). Sheridan’s delegation clause, read within the arbitration section, remained tied to her own use. Neither broad delegation language nor incorporation of AAA rules established her consent, as beneficiary or representative, to delegate claims arising solely from Mark’s use (¶¶ 42–45, 63).\n\nFAA section 2 reinforced that contractual connection: these claims arose from Mark’s distinct transaction, leaving the statutory foundation for enforcing Sheridan’s delegation unmet (¶¶ 47–49). *Henry Schein* bars a “wholly groundless” exception after valid delegation, but preserves the antecedent judicial inquiry into consent. The court resolved that inquiry rather than weighing an arbitration argument after established delegation (¶¶ 54–60, 62).\n\nThe court then decided underlying arbitrability. Sheridan was not a signatory to Mark’s agreement, and her individual agreement expressed no consent to arbitrate this third-person-use wrongful death dispute in her representative or beneficiary capacity. Uber established neither delegation nor agreement to arbitrate the underlying claims (¶¶ 72–74).\n\n## Disposition and limits\n\nThe court reversed the appellate judgment, affirmed the circuit judgment, and remanded. Wrongful death proceedings may resume; survival counts remain voluntarily dismissed (¶¶ 76–79). It expressly declined to decide procedural or substantive unconscionability (¶ 74). Its decision addresses arbitration, leaving the pleaded negligence and wrongful death merits for further proceedings (¶¶ 6, 76). The court acknowledged a fine distinction between delegation scope and initial consent, and inconsistent decisions elsewhere (¶ 67).\n",
      "download": "/documents/field-tests/run-3.txt",
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      "wordCount": 655,
      "startedAt": "2026-10-04T03:59:52Z",
      "completedAt": "2026-10-04T04:01:27Z",
      "summary": "Core distinctions preserved; citation support needs attention"
    }
  ],
  "checks": [
    {
      "id": "identity",
      "title": "Case, court, citation, and filing date",
      "paragraphs": "Caption; ¶¶1–3",
      "pdfPage": 1,
      "expected": "Geller v. Uber Technologies, Inc., 2026 IL 132066 is an Illinois Supreme Court opinion filed September 24, 2026. The caption supplies the date and formal citation; paragraphs 1–3 identify the litigation and result.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "Geller v. Uber Technologies, Inc., 2026 IL 132066 (Ill. Sept. 24, 2026). Sheridan appealed as independent administrator of Mark Geller’s estate. (¶¶ 1–3.)",
          "note": "The case, citation, court abbreviation, filing date, and representative capacity agree with the caption and paragraphs 1–3. The filing date is in the caption, rather than paragraphs 1–3; this source-pointer issue is assessed under paragraph support."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "*Geller v. Uber Technologies, Inc.*, 2026 IL 132066 (Ill. Sept. 24, 2026).",
          "note": "The caption confirms all four identifying details. The response gives no source pointer in this citation line; that presentation issue is assessed under paragraph support."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "*Geller v. Uber Technologies, Inc.*, 2026 IL 132066, Illinois Supreme Court, opinion filed September 24, 2026 (caption; ¶¶ 1–3).",
          "note": "The identifying details agree with the caption. The response expressly identifies the caption as the source for the date and citation."
        }
      ]
    },
    {
      "id": "facts",
      "title": "The accident and the two users",
      "paragraphs": "¶¶1–3, 6–10",
      "pdfPage": 1,
      "expected": "Mark requested the Uber trip and died in the crash; Sheridan sued as independent administrator. Her individual Uber agreement concerns her own use, while the wrongful-death dispute arose from Mark’s use.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "On April 19, 2022, Mark requested an Uber ride. His driver, Ejaz Rathore, lost control on an expressway; the crash fatally injured both men. Sheridan, Mark’s spouse and estate administrator, sued Uber Technologies, Inc., its subsidiary Rasier, LLC, and Rathore, alleging driver negligence, Uber’s vicarious liability, negligence through res ipsa loquitur, survival claims, and wrongful death claims for Mark’s statutory next of kin. (¶¶ 1, 6.)",
          "note": "Paragraphs 1 and 6 support the crash, deaths, parties, representative role, and allegations. The following agreement paragraph and later reasoning distinguish Sheridan’s own use from Mark’s trip. The agreement citation requires a narrower check under paragraph support."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "On April 19, 2022, Mark Geller requested an Uber ride. Driver Ejaz Rathore lost control on an expressway; the resulting crash fatally injured both men. Gloria Sheridan Geller (Sheridan), Mark’s widow and independent estate administrator, sued Rathore and Uber Technologies, Inc., together with its subsidiary Rasier, LLC (collectively, Uber), alleging driver negligence, Uber’s vicarious liability, negligence through res ipsa loquitur, survival claims, and wrongful death claims for Mark’s statutory next of kin. (¶¶ 1, 6.)",
          "note": "The account matches paragraphs 1 and 6, and attributes negligence to the complaint rather than treating it as an adjudicated finding. The response separately describes Sheridan’s agreement and Mark’s use."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "Gloria Sheridan Geller, Mark’s spouse, acted as independent administrator and wrongful death beneficiary. These capacities differed from her capacity as an individual Uber user. As personal representative, she was the nominal plaintiff pursuing wrongful death claims for statutory beneficiaries, including herself and any other next of kin (¶¶ 24–25).",
          "note": "Paragraphs 24–25 support these capacities and beneficiary interests. The preceding paragraph correctly describes Mark’s trip, crash, and allegations under paragraphs 1 and 6; the agreement paragraph distinguishes the two users."
        }
      ]
    },
    {
      "id": "survival",
      "title": "Survival counts remain dismissed",
      "paragraphs": "¶¶10, 76",
      "pdfPage": 6,
      "expected": "The circuit court compelled survival arbitration based on Mark’s executed agreement; the estate voluntarily dismissed those counts. Paragraph 76 says they remain dismissed on remand.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "The circuit court compelled arbitration of survival claims under Mark’s agreement, denied arbitration of wrongful death claims, and stayed those claims pending survival arbitration. The estate then voluntarily dismissed its survival actions. (¶¶ 7, 10.)",
          "note": "Paragraph 10 supports the arbitration order and voluntary dismissal. The disposition paragraph also expressly says the survival counts remain voluntarily dismissed, consistent with paragraph 76."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "The Cook County circuit court compelled arbitration of survival claims under Mark’s agreement, denied arbitration of wrongful death claims under Sheridan’s agreement, and stayed the latter pending survival arbitration. The estate then voluntarily dismissed the survival claims. (¶ 10.)",
          "note": "This matches paragraph 10. The final section repeats that survival counts remain voluntarily dismissed, as paragraph 76 requires."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "The circuit court compelled arbitration of survival claims under Mark’s agreement, denied arbitration of wrongful death claims, and initially stayed those claims pending survival arbitration. It then granted the estate’s voluntary dismissal of the survival actions (¶ 10).",
          "note": "Paragraph 10 supports each procedural step. The final section also preserves paragraph 76’s statement that the survival counts remain voluntarily dismissed."
        }
      ]
    },
    {
      "id": "procedure",
      "title": "The three courts and the result",
      "paragraphs": "¶¶10–16, 76–79",
      "pdfPage": 6,
      "expected": "The circuit court denied wrongful-death arbitration; the First District reversed; the Illinois Supreme Court reversed the appellate judgment, affirmed the circuit judgment, and remanded.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "The Supreme Court reversed the appellate judgment, affirmed the circuit court, and remanded. Wrongful death proceedings may resume in circuit court; survival counts remain voluntarily dismissed. The court expressly declined procedural and substantive unconscionability arguments. (¶¶ 74, 76–79.)",
          "note": "The response’s procedural-history section gives the circuit and appellate decisions; this final account matches paragraphs 76–79 and keeps resumed wrongful-death proceedings separate from dismissed survival counts."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "The Supreme Court reversed the appellate judgment, affirmed the circuit court, and remanded. Wrongful death proceedings may resume; survival counts remain voluntarily dismissed. (¶¶ 76–79.)",
          "note": "The preceding history correctly identifies the circuit denial and First District reversal. This disposition matches paragraphs 76–79."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "The court reversed the appellate judgment, affirmed the circuit judgment, and remanded. Wrongful death proceedings may resume; survival counts remain voluntarily dismissed (¶¶ 76–79).",
          "note": "The history distinguishes the circuit and appellate decisions, and the final disposition tracks paragraphs 76–79 without turning reversal into a merits judgment."
        }
      ]
    },
    {
      "id": "delegation",
      "title": "Who decides comes before whether to arbitrate",
      "paragraphs": "¶¶29–33, 62–63, 70–72",
      "pdfPage": 21,
      "expected": "The court separately examines consent to delegate arbitrability and, absent delegation, arbitration of the underlying wrongful-death dispute. It resolves the antecedent consent question rather than applying a wholly-groundless exception.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "No on both questions. The court first had to decide whether the parties consented to delegate this dispute; absent that consent, the court also decided that the wrongful death claims were not subject to arbitration. (¶¶ 29, 70, 72–74.)",
          "note": "Paragraph 29 states the two questions; paragraphs 70 and 72–74 give their answers. The later Henry Schein discussion also preserves paragraph 62’s distinction between initial consent and a forbidden wholly-groundless merits screen."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "*Henry Schein* prohibits courts from disregarding an established delegation because arbitration appears wholly groundless. This decision instead resolved antecedent consent.",
          "note": "This distinction agrees with paragraphs 54–60 and 62. The issues and subsequent underlying-arbitration paragraph separately address the two questions in paragraphs 29 and 72–74."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "*Henry Schein* bars a “wholly groundless” exception after valid delegation, but preserves the antecedent judicial inquiry into consent. The court resolved that inquiry rather than weighing an arbitration argument after established delegation (¶¶ 54–60, 62).",
          "note": "The response correctly describes the sequence in paragraphs 54–60 and 62, then separately addresses underlying arbitration under paragraphs 72–74."
        }
      ]
    },
    {
      "id": "capacity",
      "title": "Capacity and contractual use stay separate",
      "paragraphs": "¶¶63, 67, 73–74",
      "pdfPage": 21,
      "expected": "Sheridan’s own-use agreement did not show consent as wrongful-death beneficiary or estate representative to delegate or arbitrate claims from Mark’s use. She did not sign Mark’s agreement.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "For underlying arbitration, Sheridan did not agree in her beneficiary or representative capacity to arbitrate claims arising from Mark’s use, was a nonsignatory to his agreement, and had no corresponding commitment in her individual agreement. Uber therefore failed to establish consent to arbitrate the wrongful death dispute itself. (¶¶ 73–74.)",
          "note": "This tracks paragraphs 73–74. The earlier account also distinguishes all three capacities under paragraphs 24–28 and connects delegation to her own use under paragraphs 35–44."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "After resolving delegation, the court separately rejected arbitration of the underlying claims. Sheridan did not sign Mark’s agreement, and her own agreement signaled no consent, as beneficiary or representative, to arbitrate wrongful death arising from another person’s use. Uber established neither beneficiary nor estate consent. (¶¶ 72–74.)",
          "note": "Paragraphs 72–74 support the nonsignatory status and lack of beneficiary or representative consent. The response does not merge Sheridan’s individual customer role with the interests she represents."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "The court then decided underlying arbitrability. Sheridan was not a signatory to Mark’s agreement, and her individual agreement expressed no consent to arbitrate this third-person-use wrongful death dispute in her representative or beneficiary capacity. Uber established neither delegation nor agreement to arbitrate the underlying claims (¶¶ 72–74).",
          "note": "The account accords with paragraphs 72–74, while its earlier delegation paragraph also cites paragraph 63 for the lack of consent in the beneficiary and representative capacities."
        }
      ]
    },
    {
      "id": "limits",
      "title": "Unconscionability and merits remain open",
      "paragraphs": "¶¶74–76",
      "pdfPage": 25,
      "expected": "The Supreme Court did not reach procedural or substantive unconscionability. The result concerns the agreement and claims before it, without deciding negligence liability or declaring all Uber or wrongful-death arbitration invalid.",
      "results": [
        {
          "run": 1,
          "status": "Covered",
          "excerpt": "The decision rests on Sheridan’s agreement and these claims’ source. The court acknowledged a fine line between delegation scope and consent, and inconsistent decisions. Wrongful death liability remains for further proceedings. (¶¶ 67, 76.)",
          "note": "The response’s preceding paragraph expressly says unconscionability was not reached under paragraph 74. This qualification preserves paragraph 67’s doctrinal boundary and paragraph 76’s case-specific remand; it does not announce a universal arbitration ban."
        },
        {
          "run": 2,
          "status": "Covered",
          "excerpt": "It expressly declined to reach procedural or substantive unconscionability. (¶ 74.) Its holding rests on this agreement and these distinct uses and capacities; the court acknowledged a fine distinction between delegation scope and consent, and inconsistent decisions elsewhere. (¶¶ 67, 76.)",
          "note": "Paragraph 74 expressly leaves unconscionability undecided. Paragraphs 67 and 76 support the case-specific qualification. Nothing in the response declares Uber’s agreements universally invalid or treats pleaded negligence as established liability."
        },
        {
          "run": 3,
          "status": "Covered",
          "excerpt": "It expressly declined to decide procedural or substantive unconscionability (¶ 74). Its decision addresses arbitration, leaving the pleaded negligence and wrongful death merits for further proceedings (¶¶ 6, 76). The court acknowledged a fine distinction between delegation scope and initial consent, and inconsistent decisions elsewhere (¶ 67).",
          "note": "The response ties the unaddressed arguments to paragraph 74, allegations and remand to paragraphs 6 and 76, and the doctrinal qualification to paragraph 67. It keeps arbitration disposition separate from negligence liability."
        }
      ]
    },
    {
      "id": "support",
      "title": "A correct proposition still needs the right source pointer",
      "paragraphs": "Caption; ¶¶8–10; full supplied opinion",
      "pdfPage": 3,
      "expected": "Each material proposition should point to supporting source text. Paragraph 8 reports Uber’s assertion of agreements; paragraph 9 quotes Sheridan’s text; paragraph 10 confirms Mark’s execution and says his agreement is not reproduced. The caption supplies the filing date. Authorities discussed by the opinion are not independently checked research.",
      "results": [
        {
          "run": 1,
          "status": "Needs attention",
          "excerpt": "Mark and Sheridan individually accepted separate Uber agreements. Sheridan’s agreement covered disputes connected to her own use, access, and relationship with Uber, including third-party claims related to her use. It delegated threshold arbitrability questions to an arbitrator and incorporated AAA rules. (¶¶ 8–9, 42–43.)",
          "note": "The agreement proposition is consistent with the opinion as a whole, but this pointer compresses an attribution distinction: paragraph 8 reports Uber’s assertion, paragraph 9 reproduces Sheridan’s text, and paragraph 10 expressly confirms Mark’s execution while saying his agreement is not reproduced. Add paragraph 10 and preserve that limit. The Citation section also gives the correct filing date without identifying its caption source; paragraphs 1–3 do not state that date. No invented authority or claim of independent treatment research was identified in this comparison."
        },
        {
          "run": 2,
          "status": "Needs attention",
          "excerpt": "Mark and Sheridan separately accepted Uber agreements containing arbitration provisions. Sheridan’s agreement covered disputes involving her access, use, or relationship with Uber, including third-party claims related to her use; it also assigned threshold arbitrability questions to an arbitrator. (¶¶ 8–9.)",
          "note": "Paragraph 8 reports Uber’s assertion, while paragraph 9 supplies Sheridan’s language. Paragraph 10 is the clearer source for Mark’s executed agreement and expressly says its text is not reproduced. The response should add that source and limit rather than imply that both agreements’ text is available. Its correct citation line gives no pointer to the caption for the filing date. These are source-reference and completeness issues; the shared agreement fact itself is not an invented fact."
        },
        {
          "run": 3,
          "status": "Needs attention",
          "excerpt": "Mark and Sheridan separately accepted Uber agreements containing arbitration provisions. Sheridan’s agreement addressed her own use, access, and relationship with Uber; third-party claims were covered when related to her use. It also assigned threshold arbitrability questions to an arbitrator and incorporated AAA rules and the FAA (¶¶ 8–9, 42–43).",
          "note": "The caption is correctly identified elsewhere for the filing date. This agreement passage still relies on paragraph 8’s account of Uber’s assertion and paragraph 9’s Sheridan-only quotation. Add paragraph 10’s confirmation of Mark’s execution and its express statement that his agreement is not reproduced. The response does not claim to quote both complete contracts, but omits this source limitation. No independently verified authority or later-treatment claim was identified."
        }
      ]
    }
  ],
  "prompt": "You are producing one observed response for a source-supplied appellate case-briefing experiment. Use only the complete text at /Users/jtnessler/Documents/Business/Integrated Cognition/Website Development/Integrated Cognition LLC/public/documents/field-tests/geller-source.txt. Read that file in full. Do not browse, read other files, use an answer key, or consult other agents. Do not edit the source.\n\nWrite a 500–700 word case brief for a lawyer reading this opinion for the first time. Use these six headings: Citation; Material facts; Procedural history; Issues; Holding and reasoning; Disposition and limits. Cite the opinion's numbered paragraphs for every material factual or legal proposition. Keep the parties' legal capacities, distinct claims, and decision-making roles clear. Explain what the court actually decided and identify any issues it expressly did not decide. Do not claim to have checked later treatment or current validity. If the supplied text does not support a proposition, say so rather than filling the gap.\n\nReturn only the case brief in your final response. Do not include a score, commentary about this experiment, or private reasoning. Save exactly that final case brief as UTF-8 text in your assigned output file, and return the same text. The assigned output path is supplied separately as execution administration; it is not part of the case-brief prompt. Record only UTC start/end times and the source SHA-256 in your assigned metadata file. No legal review time or API cost was measured.",
  "answerHeading": "The core holding survived. The citations still need checking.",
  "answer": "Yes, these three source-supplied runs produced briefs that preserved the main holding and the distinction between survival and wrongful-death claims. The source comparison also found citation support that should be tightened. A correct-looking result is a draft for legal review, not evidence that AI case briefs are generally reliable.",
  "scopeNote": "This is a small documented case study: one opinion, one prompt, one configured model alias, and three responses. It does not establish a general accuracy rate, current legal validity, or time saved.",
  "comparisonIntroduction": "The eight criteria below were recorded before generating the briefs. Expand a check to see the exact response excerpt and the source-linked observation for each run. This comparison was prepared with AI assistance; Jonathan Nessler has not yet completed the legal review.",
  "configuration": [
    {
      "name": "Input",
      "value": "Complete layout-extracted text from all 26 pages of the supplied opinion PDF; PDF page markers retained."
    },
    {
      "name": "Environment",
      "value": "Three fresh Codex desktop delegated workspace agents; no prior conversation supplied. Inherited platform instructions and tool access remain present."
    },
    {
      "name": "Model configuration",
      "value": "Runtime-reported parent configuration: gpt-6.1-sol, reasoning effort ultra; inherited by the three agents. An immutable model snapshot was not exposed."
    },
    {
      "name": "Task constraints",
      "value": "Source only; no browsing, other files, answer key, or consultation with other agents. The file-reading and output-saving tools were permitted."
    },
    {
      "name": "Sampling controls",
      "value": "Temperature and random seed were not exposed. No vendor comparison or controlled API benchmark was performed."
    },
    {
      "name": "Run selection",
      "value": "All three planned runs retained. No response was retried or selected for quality."
    },
    {
      "name": "Measurement",
      "value": "UTC task start and end timestamps recorded. These include workspace activity and are not isolated inference times. Lawyer review time and API cost were not measured."
    }
  ],
  "downloads": [
    {
      "path": "/documents/field-tests/evidence-packet.zip",
      "label": "Complete evidence packet",
      "format": "ZIP · source, protocol, outputs & worksheet",
      "download": true
    },
    {
      "path": "/documents/field-tests/reviewer-worksheet.pdf",
      "label": "Blank legal-review worksheet",
      "format": "PDF · printable",
      "download": true
    },
    {
      "path": "/documents/field-tests/geller-2026-il-132066.pdf",
      "label": "Supplied opinion",
      "format": "PDF · 26 pages",
      "download": true
    },
    {
      "path": "/documents/field-tests/geller-source.txt",
      "label": "Exact extracted input",
      "format": "TXT · all 26 pages",
      "download": true
    },
    {
      "path": "/documents/field-tests/protocol.json",
      "label": "Frozen test protocol",
      "format": "JSON · prompt & eight criteria",
      "download": true
    },
    {
      "path": "/documents/field-tests/observations.json",
      "label": "Runs and comparison notes",
      "format": "JSON · raw responses & provenance",
      "download": true
    }
  ]
}