What was hallucinated

Fabricated: Case Law | Appellants cited State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 (2019), which the court could not locate and treated as a likely fabricated citation. || Misrepresented: Case Law | Richmonds cited Osborn v. Mason County for a proposition about mandatory plumbing inspections, but the case concerns a duty to warn and does not contain the stated plumbing/inspection holding; court held the citation does not support the proposition. || False Quotes: Case Law | Richmonds quoted language attributed to Bailey v. Town of Forks that does not appear in that opinion; court noted the quoted language is not in Bailey. || False Quotes: Case Law | Richmonds attributed a municipal-immunity-related quotation to Phillips v. King County that the court found does not appear in that case. || Fabricated: Case Law | Appellants cited King County v. Vincent (167 Wn.2d 671 (2009)), which the court could not locate and treated as a likely fabricated citation. || Fabricated: Case Law | Appellants cited Carlyle v. Dep't of Soc. & Health Servs., 155 Wn. App. 895, 231 P.3d 218 (2010), which the court could not locate and treated as a likely fabricated citation.

Sanction teardown · CA Washington (d3), USA · 2026-03-17

Gregory Richmond and Lynne Richmond v. City of Newport, Washington

What happened

In CA Washington (d3), USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Appellants cited State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 (2019), which the court could not locate and treated as a likely fabricated citation.
Misrepresented (Case Law)

Richmonds cited Osborn v. Mason County for a proposition about mandatory plumbing inspections, but the case concerns a duty to warn and does not contain the stated plumbing/inspection holding; court held the citation does not support the proposition.
False Quotes (Case Law)

Richmonds quoted language attributed to Bailey v. Town of Forks that does not appear in that opinion; court noted the quoted language is not in Bailey.
False Quotes (Case Law)

Richmonds attributed a municipal-immunity-related quotation to Phillips v. King County that the court found does not appear in that case.
Fabricated (Case Law)

Appellants cited King County v. Vincent (167 Wn.2d 671 (2009)), which the court could not locate and treated as a likely fabricated citation.
Fabricated (Case Law)

Appellants cited Carlyle v. Dep't of Soc. & Health Servs., 155 Wn. App. 895, 231 P.3d 218 (2010), which the court could not locate and treated as a likely fabricated citation.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Not specified in source record.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1690/Richmond_USA_17_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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