Courts on AI / Fabricated or misquoted citations
Cabrera Thompson v. Seattle Public Schools
United States District Court for the Western District of Washington · Federal district courts · WA · · No. 2:25-cv-00468-TL · order
On 2026-03-31, U.S. District Court for the Western District of Washington granted leave to amend only in part and ordered the plaintiff to show cause within seven days for continued citation of nonexistent authority. A self-represented party submitted a motion with fabricated or nonexistent authorities.
- Disposition
- The court granted in part and denied in part plaintiff’s motion to amend and ordered plaintiff to show cause within seven days why sanctions should not issue for continued citation of nonexistent authority.
- Recorded conduct
- Plaintiff’s proposed second amended complaint cited Shumway v. Wright, No. 2:19-cv-00519-RSL, for a negligent-misrepresentation proposition; that docket number belonged to Christophe v. Nunn, and the court found no Shumway v. Wright in the district. — outcome: pending; 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.
SAC are the same as the claims brought in her FAC, except that Plaintiff appears to seek to add an additional Defendant (WSRMP) to Counts Three and Five. Dkt. No. 96-3 at 36–46. Further, Plaintiff seeks to add 11 new claims (Counts Seven through Seventeen). Id. at 47–64. Plaintiff does not specify which claims are brought against which Defendants. It appears, however, that Plaintiff intends to plead all 11 new claims against Defendant SPS, and some of them against Defendant WSRMP. As the Court has now granted Plaintiff additional time to join parties (see Dkt. No. 155; see also supra n.1.), in evaluating Plaintiff’s motion here, the Court will consider claims to have been pleaded against WSRMP where the language of the proposed SAC lends itself to such an interpretation. These appear to be Counts Three, Five, Seven, Ten, Eleven, and Sixteen. Defendant variously asserts Although the Court issued a case scheduling order (Dkt. No. 83) before Plaintiff filed the instant motion (Dkt. No. 96), Rule 15’s liberal amendment standard applies here. Ninth Circuit authority indicates that the “good cause” standard of Rule 16 applies when a Party seeks to
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