Courts on AI / Fabricated or misquoted citations
Put A Bird On It, LLC v. Seattle Arena Holdings, LLC
Court of Appeals of Washington · State appellate courts · WA · · 2026 WL 579399 · No. No. 87756-9-I · opinion
Washington Court of Appeals on 2026-03-02 in Put A Bird On It, LLC v. Seattle Arena Holdings, LLC found counsel's opening brief included several AI-generated erroneous citations and false quotations with mismatched captions, citations, and legal principles. The court affirmed dismissal of the contract claims with prejudice and noted counsel's AI-based erroneous citations and false quotations.
- Disposition
- The court affirmed dismissal of the contract claims with prejudice and noted counsel's AI-based erroneous citations and false quotations.
- Recorded conduct
- Counsel's opening brief included several AI-generated erroneous citations and false quotations with mismatched captions, citations, and legal principles. — outcome: other; actor: lawyer
- 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.
2 While not germane to our substantive analysis, the court notes that appellant's opening brief included several erroneous citations that the responsible attorneys at Corr|Downs PLLC have since indicated were generated by “AI-based search engines.” The citations for these cases appear to be a compilation of (a) a real or fictitious caption, (b) citations to other entirely different cases, and (c) legal principles that cannot reasonably be found in the cited cases. The conduct leading to these citations falls below our expectations of counsel, particularly since it is now well known in the legal community that AI resources can generate erroneous citations and false quotations. Understanding the gravity of this conduct, the responsible attorneys have taken steps to remediate the situation, have apologized to the court, and have represented that they are implementing additional quality-control protocols (as all lawyers should) to ensure this does not happen again.
Authorities cited in the passage: AI-based search engines