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Courts on AI / Fabricated or misquoted citations

Gregory Richmond and Lynne Richmond v. City of Newport, Washington

Washington Court of Appeals, Division III · State appellate courts · WA · · 2026 WL 746700 · No. 40954-6-III · opinion

Fabricated or misquoted citations

On 2026-03-17, Washington Court of Appeals, Division III affirmed dismissal and warned self-represented appellants that cases cited for convenient propositions must be real and supportive. A self-represented party submitted an appellate brief with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 and Osborn v. Mason County.

Disposition
The court affirmed dismissal and warned self-represented appellants that cases cited for convenient propositions must be real and supportive.
Recorded conduct
The appellate brief used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 and Osborn v. Mason County, which the court found nonexistent, misquoted, or unsupported. — outcome: other; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Freedom of Information Act, 5 U.S.C. § 552. The Richmonds do not argue that the trial court erred in dismissing their intentional infliction of emotional distress or their Consumer Protection Act claims. The Richmonds likely used AI for their briefing. AI is notorious for fabricating opinions and/or quotes. Here, the Richmonds cited an actual opinion, Osborn, for a proposition that would be convenient for them but which does not appear in the case. This pattern repeats with other cases cited by the Richmonds. AI fabrications occur by prompting a generative AI for a specific holding, and AI fabricating a result. This explains other cases cited by the Richmonds—King County v. Vincent, 167 Wn.2d 671 (2009), Carlyle v. Dep't of Soc. & Health Servs., 155 Wn. App. 895, 231 P.3d 218 (2010), and State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 (2019)—none of which this court could locate. We expect all parties, including pro se litigants, to ensure that the cases cited be real cases that plausibly support the proposition for which they are cited.

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