Dana Serine Greene v. GSK PLC
W.D. Washington · Jan 29, 2026
What happened in this matter?
The court denied the plaintiff's motion for court-assisted service and issued a warning regarding her use of AI-generated or hallucinated legal citations, cautioning that future submissions of non-existent authority could result in formal sanctions under Rule 11.
- Why the court cared
- Misrepresented: Case Law | Plaintiff cited Brockmeyer v. May but the authority does not support the proposition or contain the quoted text; court identified it among inaccurate/misused citations. || Misrepresented: Case Law | Plaintiff cited Freedom Watch, Inc. v. OPEC but the opinion does not contain the text she quotes; court listed it as an inaccurate citation. || Misrepresented: Case Law | Plaintiff cited Porsche Cars N. Am., Inc. v. Porsche.net and allegedly misquoted or misapplied its text; court flagged it as not supporting her proposition. || Misrepresented: Case Law | Plaintiff cited Gurung v. Malhotra but the text cited is not present in that authority; court included it among suspect citations. || Misrepresented: Case Law | Plaintiff cited In re LLS Am., LLC but the court found the citation did not support her quoted text and listed it among problematic citations. || Fabricated: Case Law | The opinion contains multiple citation references that are incorrect or do not actually exist; Editor's Note preserves these invalid citations as part of the record.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in W.D. Washington, with the listed outcome: Warning.
Why this matter is tracked
In a pro se tort action against GSK PLC, the plaintiff moved for court-assisted service of process under Rule 4(c)(3). In her motion, the plaintiff cited several legal authorities that the court found were either misrepresented or did not exist. The court denied the motion for court-assisted service, noting that the plaintiff could utilize other competent forwarding authorities under the Hague Service Convention. Regarding the citations, the court observed that they bore the hallmarks of generative AI-driven hallucinations. The court issued a formal warning to the plaintiff, reminding her of her obligations under Federal Rule of Civil Procedure 11 to ensure that legal contentions are warranted by existing law and that citations are accurate.
This record documents a Pro Se Litigant filing issue in W.D. Washington, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The court identified the citations as bearing the hallmarks of generative AI.
Order denying plaintiff's motion for court-assisted service of process.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Plaintiff cited Brockmeyer v. May but the authority does not support the proposition or contain the quoted text; court identified it among inaccurate/misused citations.
- Misrepresented: Case Law | Plaintiff cited Freedom Watch, Inc. v. OPEC but the opinion does not contain the text she quotes; court listed it as an inaccurate citation.
- Misrepresented: Case Law | Plaintiff cited Porsche Cars N. Am., Inc. v. Porsche.net and allegedly misquoted or misapplied its text; court flagged it as not supporting her proposition.
- Misrepresented: Case Law | Plaintiff cited Gurung v. Malhotra but the text cited is not present in that authority; court included it among suspect citations.
- Misrepresented: Case Law | Plaintiff cited In re LLS Am., LLC but the court found the citation did not support her quoted text and listed it among problematic citations.
- Fabricated: Case Law | The opinion contains multiple citation references that are incorrect or do not actually exist; Editor's Note preserves these invalid citations as part of the record.
Questions this record answers
- What happened in Dana Serine Greene v. GSK PLC?
- The court denied the plaintiff's motion for court-assisted service and issued a warning regarding her use of AI-generated or hallucinated legal citations, cautioning that future submissions of non-existent authority could result in formal sanctions under Rule 11.
- Why does Dana Serine Greene v. GSK PLC matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in W.D. Washington, with the listed outcome: Warning.
- What does the public record establish about Dana Serine Greene v. GSK PLC?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Dana Serine Greene v. GSK PLC summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.