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Courts on AI / Fabricated or misquoted citations

Sarah & Regina Alonso v. Jackson

U.S. District Court for the Western District of Washington · Federal district courts · WA · · 2026 WL 747745 · No. 3:25-cv-05594-JHC Lucas Jackson · other

Fabricated or misquoted citations

On 2026-03-17, U.S. District Court for the Western District of Washington granted the motion to dismiss claims against one defendant and warned counsel that another fictitious authority would trigger a sanctions show-cause order. Counsel submitted a motion with fabricated or nonexistent authorities, including Allen v. Bayshore Mall.

Disposition
The court granted the motion to dismiss claims against one defendant and warned counsel that another fictitious authority would trigger a sanctions show-cause order.
Recorded conduct
The motion used fabricated or nonexistent authorities, including Allen v. Bayshore Mall, which the court found nonexistent, misquoted, or unsupported. — outcome: warning; 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.

(1). In Washington, a corporation (or “represented entity,” SARAH and REGINA ALONSO, Plaintiffs, v. JAMES JACKSON,..., Slip Copy (2026) to show cause relating to use of fictitious legal authority do not request any relief in connection with this potentially generated by AI). fake case. Whether or not generative AI was used, “[c]iting nonexistent case law or misrepresenting the holdings of a case is making IV CONCLUSION a false statement to a court.” United States v. Hayes, 763 F. Supp. 3d 1054, 1067 (E.D. Cal. 2025), reconsideration *5 For the reasons above, the Court GRANTS Nesiamotu's denied, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025) (citation motion, Dkt. # 239, and DISMISSES the claims against omitted). Such conduct is sanctionable. Id. at 1071. Nesiamotu without prejudice for insufficiency of process. If, notwithstanding this ruling, Plaintiffs consider seeking relief The Court agrees that the “Allen v. Bayshore Mall” case cited to keep Nesiamotu as a defendant in this matter, the Court by Plaintiffs cannot be located online and that circumstances cautions them to review (1) the requirements for service of suggest, but do not prove, the possibility of improper process; (2) any

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