Courts on AI / Fabricated or misquoted citations
Ward v. Amazon.com Services LLC
U.S. District Court for the Western District of Washington · Federal district courts · WA · · No. C25-1671-KKE · order
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 the arbitration-related relief and warned the plaintiff that further fictitious legal authority could produce an order to show cause for sanctions.
- Recorded conduct
- The motion used fabricated or nonexistent authorities and mischaracterized authorities, including Gile v. Dolgen Cal., LLC and Britton v. Co-op Banking Grp., 4 F.4th 742, which the court found nonexistent, misquoted, or unsupported. — 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
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