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Courts on AI / Fabricated or misquoted citations

Merz v. City of Kalama

United States District Court for the Western District of Washington · Federal district courts · WA · · 2026 WL 411837 · No. NO. C24-5588 BHS · order

Western District of Washington on 2026-02-13 in Merz v. City of Kalama found the self-represented party's briefing misused Caruso for a per se defamation point and gave an inaccurate Sorensen citation later corrected to Norg. The court granted the motions to dismiss and for judgment on the pleadings, struck improper notices, and dismissed all claims with prejudice.

Disposition
The court granted the motions to dismiss and for judgment on the pleadings, struck improper notices, and dismissed all claims with prejudice.
Recorded conduct
The self-represented party's briefing misused Caruso for a per se defamation point and gave an inaccurate Sorensen citation later corrected to Norg. — 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.

comic book collection to the Kalama Public Library. In July (9) Outrage. Dkt. 27. 2021 the proffered donation was discussed at the library board meeting, which Merz attended (on Zoom). Merz alleges that he was made to feel unwelcome at this meeting, and that II. HOUSEKEEPING “Jenkins stated that Plaintiff was not an appropriate person As an initial matter, the Court previously rejected Defendants’ to be volunteering with children or selecting comic books objections about the length and timing of Merz's Response, for children.” Dkt. 27 at 11. He alleges Jenkins performed and denied Merz's motion to strike. Dkt. 60. It left open a “background check” on Merz, seeking to find a reason to the issue of Merz citing to fabricated, inaccurate authority: reject the comic book donation. Id. at 10. “In Sorensen v. City of Bellingham, 15 Wn. App. 2d 730, 733, 478 P.3d 1110 (2020), the court held that when officers Second, in 2021, Merz was apparently the focus of a stalker affirmatively act in a way that leaves a person worse off, a named Christopher Jensen. Dkt. 27 at 13. He does not duty can arise even absent explicit assurances.” Dkt. 48 at 23. articulate why Jensen targeted him, but he does allege that Jensen threatened to murder him in an email sent to Merz's *3 Merz corrected and explained the source of the inaccurate Kalama email account, though he alleges he never saw the cite at Dkt. 52. He intended to cite Norg v. City of Seattle, email. Id. Nevertheless he alleges that the email “contained a 200 Wn.2d 749 (2023) for the same proposition. Norg did not manifesto that purported to expose plaintiff.” Id. He alleges involve analogous facts, and it is tenuous support for Merz's that “someone” deleted the email instead of forwarding it claim that any defendant is liable to him for failing to warn to law enforcement. Id. He alleges that he sought to discuss him of a known danger, particularly where no harm resulted. Jensen and his threats at various city council meetings, and Nevertheless, because the Court can resolve the motion on the Reuter muted his microphone. Id. at 16. merits, it declines to dismiss based on the inaccurate citation.

Authorities cited in the passage: per se · Sorensen v. City of Bellingham, 15 Wn. App. 2d 730, 733, 478 P.3d 1110 (2020) · Merz relied on Caruso v. Local Union 690 · Merz cited 'Sorensen v. City of Bellingham · Merz later admitted he intended to cite Norg v. City of Seattle · In Sorensen v. City of Bellingham · Dkt. 52. He intended to cite Norg v. City of Seattle

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