Sanction teardown · W.D. Washington, USA · 2025-08-28
Myeesha Parker v. Costco Wholesale Corp.
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:
-
False Quotes (Case Law)Quoted language attributed to Meissner v. Simpson Timber Co. could not be located in that existing Washington case (false quotation).
-
False Quotes (Case Law)Quote attributed to 'Blaise v. Underwood' does not appear in the (similarly named) existing case Balise v. Underwood; quoted language not located (false quotation).
-
False Quotes (Case Law)Quotation attributed to Capitol Hill Methodist Church of Seattle does not appear where cited; pincite omitted and quoted language not found (false quotation).
-
False Quotes (Case Law)In re Sheehan cited with incorrect reporter number and omissions; paragraphs from the opinion appear altered and inserted without ellipses or brackets (misquoted/altered case text).
-
False Quotes (Case Law)Scrivener v. Clark College cited with incorrect page and typographical errors; quoted language placement incorrect (misquote/pincite error).
-
Misrepresented (Case Law)Cited Supreme Court and Ninth Circuit authorities (Martel v. Clair and United States v. Emmett) used to support an "is regularly applied" formulation in the Ninth Circuit—both cases inapplicable to the asserted Rule 4(m) proposition and do not contain the quoted phrase (misapplied/misrepresented precedent).
-
False Quotes (Case Law)Beecher v. Wallace quotation reproduced with altered punctuation, capitalization, paragraph breaks, and reporter formatting differing from the original opinion (altered quote/formatting).
-
Misrepresented (Exhibits & Submissions)Counsel represented a document at Dkt. 21-3 as a declaration and quoted language that does not appear there; similar language existed in a different docketed declaration filed by Defendant—Counsel misattributed/ misquoted the record (misrepresentation of exhibits).
-
Misrepresented (Exhibits & Submissions)Investigation report from ABC Messenger Service (Exhibit 9) quoted inaccurately—Counsel added language stating the report 'ensur[ed] that each required document was presented' though the filed report does not include that assurance (misquote of exhibit).
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
Fine, Adverse Costs Order, Bar Referral (monetary penalty: 6200 USD.)
Additional detail
In a later decision, counsel was fined 3,000 USD, plus costs, which came to 3,200 USD. Counsel was also later referred to the Bar.
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://reason.com/volokh/2026/02/14/the-quality-of-counsels-filings-further-deteriorated/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).