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Courts on AI / Fabricated or misquoted citations

Medal v. Amazon.com Services, LLC

United States District Court for the Western District of Washington · Federal district courts · WA · · No. Case 2:23-cv-01975-JHC · order

Western District of Washington on 2026-03-04 in Medal v. Amazon.com Services, LLC found counsel's opening brief included erroneous citations generated by AI-based search engines, combining captions, unrelated citations, and unsupported principles. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Disposition
The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
Recorded conduct
Counsel's opening brief included erroneous citations generated by AI-based search engines, combining captions, unrelated citations, and unsupported principles. — outcome: pending; 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.

3 GRANTS the Motion and ORDERS Plaintiffs’ counsel to explain: (1) each signatory’s role in 4 the use of the “juxtaposed” language and accompanying false citation in Plaintiffs’ Opposition to 5 Defendant’s Motion to Stay (Dkt. No. 122) (“Opposition”); (2) whether and how the drafting or 6 research for the Opposition was aided by the use of generative AI; and (3) what verification 7 mechanisms were in place for use of generative AI. This explanation must be filed on or before 8 March 18, 2026. 9 IT IS SO ORDERED. 10 DATED this 4th day of March, 2026. 11 12 _ 13 JOHN H. CHUN UNITED STATES DISTRICT JUDGE

Authorities cited in the passage: 21 U.S.C. § 343(r)(6)(D)

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