Dana Serine Greene v. GSK PLC
W.D. Washington · Jan 29, 2026
- Jurisdiction
- federal
- Court
- W.D. Washington
- Record ID
- dana-serine-greene-v-gsk-plc-2026-01-29
- Observed outcome
- Motion denied; court issued a formal warning to the pro se litigant regarding the submission of hallucinated legal citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in W.D. Washington, with the listed outcome: Warning.
Failure modes and consequences
- Hallucinated_case_law
- Misrepresented_legal_authority
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- Generative artificial intelligence (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order denying plaintiff's motion for court-assisted service of process.
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
The court identified the citations as bearing the hallmarks of generative AI.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.