Courts on AI / Fabricated or misquoted citations

West v. Lower Duwamish Waterway Group

Court of Appeals of Washington, Division One · State appellate courts · WA · 2026-04-20 · 2026 WL 1069752 · No. No. 87289-3-I · opinion

Fabricated or misquoted citations

The Washington Court of Appeals on 2026-04-20 admonished the self-represented party for unverified or fabricated authorities and cautioned against repeating the citation misconduct in Arthur West v. Lower Duwamish Waterway Group. The self-represented party filed a brief with one fabricated case citation and one false case quotation.

Disposition: The summary-judgment dismissal was affirmed, and West’s motion to supplement the record was denied.
Recorded conduct: West’s pro se briefing provided fictitious quotations from existing cases; the court rebuked the lack of candor and reminded litigants to verify that citations are not invented or hallucinated by generative AI or any other source. — outcome: warning; 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.

see also Telford, 95 Wn. App. at 162 & n. 17 (discussing 1991 Att'y Gen. Op. No. 5). This is not persuasive to the instant record. 13 Atcertainpointsinhisbriefing,Westprovidesfictitiousquotationsfromexistentcases. Werebukesuchlackof candor as detrimental and offensive to the legal process and not worthy of judicial review. Everyone, including pro se litigants, are responsible to confirm their pleadings, motions, briefs, and other filings are accurate and do not contain any citations that are invented or hallucinated by generative artificial intelligence (AI) or any other source. See RAP 10. 3(a)(6); West v. Thurston County, 168 Wn. App. 162, 187, 275 P. 3d 1200 (2012).

Authorities cited in the passage: West v. Thurston County, 168 Wn

Court document: storage.courtlistener.com
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 at storage.courtlistener.com; quoted passage confirmed. Re-coded from the document 2026-09-08 (independent second read).

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