Gregory Richmond and Lynne Richmond v. City of Newport, Washington
CA Washington (d3) · Mar 17, 2026
What happened in this matter?
The court identified multiple instances of AI-generated hallucinations in the appellants' briefing, including fabricated case citations (e.g., State v. Johnson, King County v. Vincent, Carlyle v. Dep't of Soc. & Health Servs.) and misrepresented holdings in actual cases (e.g., Osborn v. Mason County, Bailey v. Town of Forks, Phillips v. King County).
- Why the court cared
- The court reasoned that the appellants' citations were likely generated by AI, which the court described as 'notorious for fabricating opinions and/or quotes.' The court observed that the appellants cited real cases for propositions that did not appear in the opinions and cited other cases that the court could not locate in any legal database. The court held that the appellants failed to provide support for their legal theories and reaffirmed the duty of all litigants to verify the authenticity and accuracy of their cited authorities.
- Why it matters now
- This case illustrates the judicial response to AI-generated hallucinations in pro se appellate filings. It reinforces the expectation that all litigants, regardless of representation status, must verify the existence and accuracy of every cited authority, as courts will not tolerate the submission of fabricated or misrepresented case law.
Why this matter is tracked
In this appeal, pro se appellants Gregory and Lynne Richmond sued the City of Newport for damages related to sewer line defects. The Court of Appeals of Washington, Division 3, affirmed the trial court's summary judgment in favor of the City, finding that the public duty doctrine barred the appellants' negligence claims. The court explicitly noted that the appellants' briefing contained multiple fabricated case citations and misrepresented legal authorities, which the court attributed to the likely use of generative AI. The court identified several non-existent cases and false quotations, emphasizing that all litigants, including those appearing pro se, are responsible for ensuring that cited authorities are genuine and accurately support the propositions for which they are cited.
This case illustrates the judicial response to AI-generated hallucinations in pro se appellate filings. It reinforces the expectation that all litigants, regardless of representation status, must verify the existence and accuracy of every cited authority, as courts will not tolerate the submission of fabricated or misrepresented case law.
Record details
What the record establishes about AI use
The court explicitly attributed the errors to the use of generative AI.
Appellate review of a trial court's grant of summary judgment in favor of the City of Newport.
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.
- Fabricated: Case Law | Appellants cited State v. Johnson, 194 Wn.2d 704, 451 P.3d 1082 (2019), which the court could not locate and treated as a likely fabricated citation.
- Misrepresented: Case Law | Richmonds cited Osborn v. Mason County for a proposition about mandatory plumbing inspections, but the case concerns a duty to warn and does not contain the stated plumbing/inspection holding; court held the citation does not support the proposition.
- False Quotes: Case Law | Richmonds quoted language attributed to Bailey v. Town of Forks that does not appear in that opinion; court noted the quoted language is not in Bailey.
- False Quotes: Case Law | Richmonds attributed a municipal-immunity-related quotation to Phillips v. King County that the court found does not appear in that case.
- Fabricated: Case Law | Appellants cited King County v. Vincent (167 Wn.2d 671 (2009)), which the court could not locate and treated as a likely fabricated citation.
- Fabricated: Case Law | Appellants cited Carlyle v. Dep't of Soc. & Health Servs., 155 Wn. App. 895, 231 P.3d 218 (2010), which the court could not locate and treated as a likely fabricated citation.
Questions this record answers
- What happened in Gregory Richmond and Lynne Richmond v. City of Newport, Washington?
- The court identified multiple instances of AI-generated hallucinations in the appellants' briefing, including fabricated case citations (e.g., State v. Johnson, King County v. Vincent, Carlyle v. Dep't of Soc. & Health Servs.) and misrepresented holdings in actual cases (e.g., Osborn v. Mason County, Bailey v. Town of Forks, Phillips v. King County).
- Why does Gregory Richmond and Lynne Richmond v. City of Newport, Washington matter for legal AI risk?
- This case illustrates the judicial response to AI-generated hallucinations in pro se appellate filings. It reinforces the expectation that all litigants, regardless of representation status, must verify the existence and accuracy of every cited authority, as courts will not tolerate the submission of fabricated or misrepresented case law.
- What does the public record establish about Gregory Richmond and Lynne Richmond v. City of Newport, Washington?
- 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.
- Which source supports this Gregory Richmond and Lynne Richmond v. City of Newport, Washington 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.