Courts on AI / Fabricated or misquoted citations
Ryan Adam Dixon v. MultiCare Health System (1)
United States District Court for the Western District of Washington · Federal district courts · WA · · 2026 WL 607769 · No. NO. CV25-5414 · opinion
Western District of Washington on 2026-03-04 in Ryan Adam Dixon v. MultiCare Health System (1) found the self-represented party's brief contained five citation defects, including Mazza v. Washoe Cnty, Shirley v. Precision Castparts Corp and Bounds v. Smith, involving nonexistent authorities, 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 brief contained five citation defects, including Mazza v. Washoe Cnty, Shirley v. Precision Castparts Corp and Bounds v. Smith, involving nonexistent authorities, 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.
Dixon's ERISA claims is DENIED. However, MultiCare's treated more favorably than parties with attorneys of record. request to compel arbitration on those claims is GRANTED. Jacobsen v. Filler, 790 F.2d 1362, 1364 (9th Cir. 1986). Dixon's ERISA claims are STAYED pending arbitration. The parties shall file a Joint Status Report within 30 days of the Dixon repeatedly cites to nonexistent cases 9 and to other completion of any arbitration. cases 10 that do not support the proposition for which they were offered. The Court has no formal rule against the use Dixon's RCW 49.52.050 wage withholding claim is of generative artificial intelligence to write pleadings and DISMISSED with prejudice. Dixon's retaliation claim is briefs. However, parties are bound by Rule 11, which requires DISMISSED without prejudice. parties to certify that their “legal contentions are warranted by existing law or by a nonfrivolous argument for extending, Dixon's motion to compel production of plan documents, Dkt. modifying, or reversing existing law or for establishing new 19, is DENIED. Dixon's motion for an extension of time, law.” Fed. R. Civ. P. 11(b)(2). Dkt. 26; and MultiCare's motion for a status or scheduling conference, Dkt. 33, are DENIED as moot. Dixon's repeated and presumably intentional failure to verify cited authority supports an award of sanctions. If, in the Dated this 4th day of March, 2026. future, Dixon repeats this behavior, monetary sanctions may be awarded. A
Authorities cited in the passage: MultiCare's treated more favorably than parties with attorneys of record. request to compel arbitration on those claims is GRANTED. Jacobsen v. Filler · Fed. R. Civ. P. 11(b)(2) · Rule 11