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Courts on AI / Fabricated or misquoted citations

Esterra Commons Venture, LLC dba Verde Esterra Park v. Justin Norton

Court of Appeals of Washington, Division One · State appellate courts · WA · · 2026 WL 734359 · No. No. 87320-2-I · opinion

Washington Court of Appeals, Division One on 2026-03-16 in Esterra Commons Venture, LLC dba Verde Esterra Park v. Justin Norton found the self-represented party's appellate brief contained four citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's appellate brief contained four citation defects involving nonexistent authorities, fabricated or misattributed quotations, mischaracterized authority. — 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.

1 Appearing pro se, Norton quotes fictitious statutory language, cites to inapplicable statutes, and relies on cases that do not exist. In the event that such fake and non-existent legal authority was generated by artificial intelligence (AI), we note this as an acknowledgment and a warning. While AI may be of assistance to parties, especially pro se litigants navigating court rules, statutes, and case law, 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 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). We hold pro se litigants to the same standard as attorneys. In re Est. of Little, 9 Wn. App. 2d 262, 274 n.4, 444 P.3d 23 (2019). 2 The commissioner reserved as to a money judgment because Verde Esterra relied on an alternate method of service. 3 Norton does not assign error or present argument as to the denial of the motion for reconsideration. See Escude v. King County Pub. Hosp. Dist. No. 2, 117 Wn. App. 183, 190 n.4, 69 P.3d 895 (2003) (“It is well settled that a party's failure to assign error to or provide argument and citation to authority in support of an

Authorities cited in the passage: West v. Thurston County

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