Amazon.com Inc. et al. v. Kathy Q. Hao et al.
W.D. Washington · Jun 15, 2026
- Jurisdiction
- federal
- Court
- W.D. Washington
- Record ID
- amazon-com-inc-et-al-v-kathy-q-hao-et-al-2026-06-15
- Observed outcome
- Motion to dismiss struck without prejudice; formal warning issued to defendant.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court struck the defendant's motion to dismiss without prejudice and issued a formal warning. The judge declined to impose monetary sanctions at this time but explicitly cautioned that future filings containing fabricated, nonexistent, or misstated authorities could result in further sanctions, including monetary penalties or additional nonmonetary directives.
The court applied the objective standard of Federal Rule of Civil Procedure 11, noting that pro se litigants who are licensed attorneys are held to the same standard of reasonable inquiry as other counsel. The court reasoned that reliance on AI-assisted research does not excuse the filing of unverified or fabricated authorities, which consume judicial resources and delay case progress.
This case reinforces that licensed attorneys, even when appearing pro se, are strictly liable under Rule 11 for the accuracy of their filings. It confirms that reliance on generative AI is not a valid defense for submitting fabricated legal authorities.
Failure modes and consequences
- Fabricated Case Law
- Nonexistent Authorities
- Misstated Statutory And Regulatory Authorities
- Failure To Verify AI Generated Research
- Fake Citations
- Fabricated Quotes
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- The court resolved Amazon's motion for an order to show cause by striking the defendant's motion to dismiss (Dkt. 6) with leave to refile.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Defendant acknowledged reliance on AI-assisted research.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all citations and legal propositions generated by AI tools.
- Ensure all filings are reviewed by counsel to confirm that cited authorities exist and support the arguments made.
- Maintain a record of the research process to demonstrate reasonable inquiry under Rule 11.
- Avoid reliance on AI-generated case law without independent verification against primary legal databases.