Skip to content

Incident Tracker / United States (federal)

Merz v. City of Kalama

·United States District Court for the Western District of Washington·US-FEDNoted, no consequenceprovisional

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.

Court
United States District Court for the Western District of Washington
Date
2026-02-13
Who used the AI
Litigant in person
AI tool
Not identified in the record
Conduct
Merz cited Sorensen v. City of Bellingham for a proposition and later corrected the source to Norg v. City of Seattle; the court found Norg tenuous and noted another misleading use of Mazzeo.
Outcome
Noted, no consequence
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Provisional — written by the court-decisions pipeline, awaiting the editor
Last checked
2026-09-07

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

  • Carter v. City of Buffalo, No. 25-CV-740 (W.D.N.Y.)2026-09-08 · US District Court, Western District of New York · WarningIn the US District Court for the Western District of New York, self-represented plaintiff Zakkiyya Carter used case law the court said did not support her propositions, after an earlier screening order. Judge John L. Si…
  • Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)2026-08-27 · US District Court, Southern District of New York · WarningIn the Southern District of New York, self-represented plaintiff Keith Ashmeade cited two nonexistent Southern District decisions while litigating discovery issues against Amazon. Magistrate Judge Reznik identified the…
  • Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)2026-08-26 · US District Court, District of Maryland · WarningIn the District of Maryland, self-represented plaintiff Darrin Johnson again cited a case the court could not locate, after an earlier Rule 11 warning. Judge Rubin said the authority appeared to be hallucinated from gen…
  • Potterf v. Wessels, No. 1:26-cv-10860-MFL-PTM (E.D. Mich.)2026-08-26 · US District Court, Eastern District of Michigan · WarningIn the Eastern District of Michigan, self-represented plaintiffs admitted using artificial intelligence to draft objections with fictitious or erroneous citations and an invented Supreme Court quotation. Judge Leitman d…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Merz v. City of Kalama”, safelegalai.com/tracker/merz-v-city-of-kalama (accessed 2026-10-07). Data: CC BY 4.0.

Report an issue with this record →