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In the Matter of the Estate of CAROL M. CAREY

Court
CA Washington
Jurisdiction
USA
Decided
2026-03-03
AI tool
Implied
Outcome
Adverse Costs Order
Monetary penalty
1 USD

What was hallucinated

Misrepresented: Case Law | Appellant cited 'In re Estate of Stoler, 113 Wn. App. 104 (2002)'; court found this citation incorrect and corresponding to State v. Neely, 113 Wn. App. 100 (a criminal case) and thus inapplicable. || Fabricated: Case Law | Appellant cited 'Estate of Wallace v. Palmer, 103 Wn. App. 1064 (2000)', which the court noted does not appear to exist. || Fabricated: Case Law | Appellant cited 'In re Estate of Powers, 255 Ill. App. 3d 1006 (1994)', which the court found does not appear to exist. || Fabricated: Case Law | Appellant cited 'McIntosh v. McIntosh, 282 Ga. 610, 652 S.E.2d 546 (2007)', which the court indicated does not appear to exist. || Fabricated: Case Law | Appellant cited 'In re Estate of Griffith, 327 P.3d 612 (Colo. 2014)', which the court determined does not appear to exist. || Misrepresented: Case Law | Appellant cited 'Perez v. Pappas, 98 Wn.2d 835, 659 P.2d 475 (1983)', which the court found inapplicable to the estate/TEDRA issues raised.

Sanction teardown · CA Washington, USA · 2026-03-03

In the Matter of the Estate of CAROL M. CAREY

What happened

In CA Washington, 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:

  • Misrepresented (Case Law)
    Appellant cited 'In re Estate of Stoler, 113 Wn. App. 104 (2002)'; court found this citation incorrect and corresponding to State v. Neely, 113 Wn. App. 100 (a criminal case) and thus inapplicable.
  • Fabricated (Case Law)
    Appellant cited 'Estate of Wallace v. Palmer, 103 Wn. App. 1064 (2000)', which the court noted does not appear to exist.
  • Fabricated (Case Law)
    Appellant cited 'In re Estate of Powers, 255 Ill. App. 3d 1006 (1994)', which the court found does not appear to exist.
  • Fabricated (Case Law)
    Appellant cited 'McIntosh v. McIntosh, 282 Ga. 610, 652 S.E.2d 546 (2007)', which the court indicated does not appear to exist.
  • Fabricated (Case Law)
    Appellant cited 'In re Estate of Griffith, 327 P.3d 612 (Colo. 2014)', which the court determined does not appear to exist.
  • Misrepresented (Case Law)
    Appellant cited 'Perez v. Pappas, 98 Wn.2d 835, 659 P.2d 475 (1983)', which the court found inapplicable to the estate/TEDRA issues raised.

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

Adverse Costs Order (monetary penalty: 1 USD.)

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/1610/In_the_Matter_of_the_Estate_of_CAREY_USA_3_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1610/In_the_Matter_of_the_Estate_of_CAREY_USA_3_March_2026.pdf

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