Matthew Merz v. Harlyn Jenkins, Jillane Baros, Melinda Finn‑Kamerath
CA Washington · Jun 15, 2026
- Jurisdiction
- state
- Court
- CA Washington
- Record ID
- matthew-merz-v-harlyn-jenkins-jillane-baros-melinda-finn-kamerath-2026-06-15
- Observed outcome
- The Court of Appeals affirmed the trial court's order granting summary judgment and awarding CR 11 sanctions against the appellant.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Washington Court of Appeals affirmed CR 11 sanctions against a pro se litigant who submitted filings containing fabricated quotations and misrepresented legal authorities. The court held that the appellant failed to meet the objective standard of reasonable inquiry required for court filings, confirming that pro se status does not excuse the submission of baseless or inaccurate legal arguments.
The linked source identifies the filing problem as: Appellant attributed a nonexistent quotation to State ex rel. McCool and presented it as authority..
The source records a concrete authority-verification problem in a state proceeding and the tribunal’s documented response to it.
Failure modes and consequences
- False Quotes: Case Law
- Misrepresented: Case Law
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Not Established
- Recorded tool
- No tool named in source
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a superior court's denial of revision of a commissioner's order, which had granted summary judgment and CR 11 sanctions.
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 current record does not establish a specific AI tool. Do not infer AI use beyond the source.
Limited to the linked source and the documented citation or quotation issue and stated disposition; no unrecorded tool, motive, or broader litigation facts are inferred.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Check the cited authority, reporter reference, and pinpoint against the primary source before filing.
- Correct any unsupported citation promptly and preserve the verification record.
- Treat the listed consequence as case-specific rather than as a general rule about AI use.