William Nelson v. Washington Board of Industrial Appeals
W.D. Washington · Jun 26, 2025
- Jurisdiction
- federal
- Court
- W.D. Washington
- Record ID
- william-nelson-v-washington-board-of-industrial-appeals-2025-06-26
- Observed outcome
- The court issued an order admonishing the plaintiff regarding AI-generated hallucinations and the necessity of verifying all citations under Rule 11.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court denied a request to formally affirm the use of AI but permitted the plaintiff to continue using it, provided he adheres to Federal Rule of Civil Procedure 11. The court issued a formal admonishment regarding the risk of AI-generated 'hallucinations' and non-existent citations, citing a prior instance where the plaintiff submitted a fabricated citation.
The court reasoned that under Fed. R. Civ. P. 11, the filer is responsible for the accuracy of all submissions, and because AI tools are known to hallucinate, the plaintiff must independently verify all citations to avoid sanctions.
This case illustrates the judicial application of Rule 11 to pro se litigants using AI. It establishes a clear expectation that users must verify AI-generated citations, with the court explicitly linking prior non-existent citations to the risk of future sanctions.
Failure modes and consequences
- Hallucination
- Fabricated_citations
- Pro Se
- Fake Citations
- Civil Rights
- Trial
- AI attribution
- Admitted
- Recorded tool
- Athena AI
- Known monetary consequence
- Not recorded
- Procedural posture
- Order addressing Plaintiff's motion to affirm use of computer software programs.
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
Plaintiff identified the software as Athena AI.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all AI-generated citations against primary legal sources.
- Ensure all filings are reviewed by a human to certify compliance with Rule 11(b) standards.
- Monitor for non-existent or hallucinated case law in any document drafted with the assistance of generative AI.