Sarah & Regina Alonso v. Jackson
W.D. Washington · Mar 17, 2026
What happened in this matter?
The court issued a formal warning to plaintiffs' counsel regarding the citation of a non-existent case, 'Allen v. Bayshore Mall.' The court explicitly cautioned that the submission of fictitious legal authority is sanctionable under Rule 11 and warned that it would issue an order to show cause if counsel again submitted such material.
- Why the court cared
- The court reasoned that citing non-existent case law constitutes a false statement to the court, which is sanctionable under Rule 11. It observed that the inability to locate the cited 'Allen v. Bayshore Mall' suggested improper oversight of generative AI or similar text-generation tools.
- Why it matters now
- One fabricated citation in a motion to amend earns a Rule 11 warning on the docket; verify before you sign, not after the court flags it.
Why this matter is tracked
In a civil rights action, the W.D. Washington court granted a motion to dismiss claims against defendant Nesiamotu, Inc. for insufficient service of process. During its review, the court identified that the plaintiffs cited a non-existent case, 'Allen v. Bayshore Mall,' in their filings. The court noted that the inability to locate this authority suggested the potential use of generative AI or other large language model tools to produce misleading legal citations. While the court did not impose immediate monetary sanctions, it issued a formal warning to plaintiffs' counsel, stating that the submission of fictitious legal authority is grounds for Rule 11 sanctions and that it would issue an order to show cause if such conduct recurred.
One fabricated citation in a motion to amend earns a Rule 11 warning on the docket; verify before you sign, not after the court flags it.
Record details
What the record establishes about AI use
The court noted the possibility of improper oversight of generative AI.
The court granted the defendant's motion to dismiss for insufficiency of service of process under Rule 12(b)(5) and issued a warning regarding the use of fictitious legal authority.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiffs cited a non-existent case "Allen v. Bayshore Mall" in support of leave to amend; Court could not locate the opinion and noted possible AI-generated fabrication, warning counsel of potential Rule 11 sanctions.
Questions this record answers
- What happened in Sarah & Regina Alonso v. Jackson?
- The court issued a formal warning to plaintiffs' counsel regarding the citation of a non-existent case, 'Allen v. Bayshore Mall.' The court explicitly cautioned that the submission of fictitious legal authority is sanctionable under Rule 11 and warned that it would issue an order to show cause if counsel again submitted such material.
- Why does Sarah & Regina Alonso v. Jackson matter for legal AI risk?
- One fabricated citation in a motion to amend earns a Rule 11 warning on the docket; verify before you sign, not after the court flags it.
- What does the public record establish about Sarah & Regina Alonso v. Jackson?
- 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 Sarah & Regina Alonso v. Jackson 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.