Courts on AI / Fabricated or misquoted citations

Ward v. Amazon.com Services LLC

United States District Court for the Western District of Washington · Federal district courts · WA · 2026-04-03 · No. C25-1671-KKE · order

Fabricated or misquoted citationscourt does not name AI

On 2026-04-03, U.S. District Court for the Western District of Washington granted the arbitration-related relief and warned the plaintiff that further fictitious legal authority could produce an order to show cause for sanctions. A self-represented party submitted a motion with fabricated or nonexistent authorities and mischaracterized authorities.

Disposition: The court granted Ward’s motions to file supplemental declarations, granted Amazon’s motion to compel arbitration, stayed the case, ordered a status report after arbitration, and warned Ward about fictitious authority.
Recorded conduct: Ward’s arbitration opposition cited a nonexistent Gile citation and a nonexistent Britton citation; the real or possible cases did not support the waiver propositions asserted. — 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.

was able to locate Gile v. Dolgen Cal., LLC, 2022 WL 17248087 (9th Cir. 2022)—but that case does not support Ward’s waiver claim. There, the Ninth Circuit found that a “motion to compel arbitration over eleven months after [Defendant] removed [the] case to federal court” amounted to waiver. 2022 WL 17248087, at *1. Such a timeline does not exist in this case. The court in Gile observed that the defendant “signed onto a joint Rule 26(f) report before filing its motion to compel,” rather than “without” moving to compel as Ward asserts. Id. (emphasis added). In any case, Gile is inapposite because here, Amazon filed its motion to compel arbitration prior to filing the joint status report. See Dkt. Nos. 30, 33. Next, and more troubling to the Court, Ward cited “Britton v. Co-op Banking Grp., 4 F.4th 742 (9th Cir. 2021)” as “finding waiver based on 77-day delay with discovery participation.” Dkt. No. 35 at 18. The Court was again unable to locate a case with that citation. The Court identified, instead, Britton v. Co-op Banking Grp. (“Briton I”), 916 F.2d 1405 (9th Cir. 1990), which supports a contrary

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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