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Mitchell Taylor Button et al. v. John Jimison (2)

Court
W.D. Washington
Jurisdiction
USA
Decided
2026-01-20
AI tool
Implied
Outcome
Struck filings
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiffs cited a Sixth Circuit case for the proposition courts may strike 'entire documents where scandalous or irrelevant matter dominates'; the court was unable to locate that case. || Fabricated: Case Law | Plaintiffs cited a case purportedly condemning efforts to label individuals as serial litigants; the court could not find the cited authority supporting that proposition. || Fabricated: Case Law | In a supplemental filing, plaintiffs cited a district court case for the proposition that a 'notice of unavailability' is not recognized in federal practice; the court was unable to locate the cited authority and the citation provided led to a different case. || Fabricated: Case Law | Plaintiffs cited two Ninth Circuit opinions for the proposition that Rule 12(b) motions must be filed before a responsive pleading; the court found the quoted language does not appear in the cited opinions and was unable to locate the authorities. || Fabricated: Case Law | Plaintiffs cited a district court case allegedly stating that striking an answer 'does not resuscitate' waived defenses; the court could not locate the cited case or quote. || Fabricated: Case Law | Plaintiffs attributed a quotation to a Ninth Circuit case claiming Rule 12(c) requires 'closed pleadings'; the court found that quote does not appear in the cited opinion.

Sanction teardown · W.D. Washington, USA · 2026-01-20

Mitchell Taylor Button et al. v. John Jimison (2)

What happened

In W.D. 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:

  • Fabricated (Case Law)
    Plaintiffs cited a Sixth Circuit case for the proposition courts may strike 'entire documents where scandalous or irrelevant matter dominates'; the court was unable to locate that case.
  • Fabricated (Case Law)
    Plaintiffs cited a case purportedly condemning efforts to label individuals as serial litigants; the court could not find the cited authority supporting that proposition.
  • Fabricated (Case Law)
    In a supplemental filing, plaintiffs cited a district court case for the proposition that a 'notice of unavailability' is not recognized in federal practice; the court was unable to locate the cited authority and the citation provided led to a different case.
  • Fabricated (Case Law)
    Plaintiffs cited two Ninth Circuit opinions for the proposition that Rule 12(b) motions must be filed before a responsive pleading; the court found the quoted language does not appear in the cited opinions and was unable to locate the authorities.
  • Fabricated (Case Law)
    Plaintiffs cited a district court case allegedly stating that striking an answer 'does not resuscitate' waived defenses; the court could not locate the cited case or quote.
  • Fabricated (Case Law)
    Plaintiffs attributed a quotation to a Ninth Circuit case claiming Rule 12(c) requires 'closed pleadings'; the court found that quote does not appear in the cited opinion.

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

Struck filings

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/1379/Button_v._Jimison_USA_20_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1379/Button_v._Jimison_USA_20_January_2026.pdf

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