Washington — AI Regulations

31 MAR 2026 · Court Case

Rosa Maria Cabrera Thompson v. Seattle Public Schools

Fabricated: Case Law | Plaintiff cited a non-existent district-court decision as precedent; the court found the docket number cited corresponded to a different case and could not locate the cited authority on the district's docket, and ordered show-cause re sanctions.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

26 MAR 2026 · Court Case

Dixon v. MultiCare Health System

Misrepresented: Case Law | Court noted this existing case was cited but does not support the proposition for which plaintiff offered it (footnote 10). || Fabricated: Case Law | Court identified this citation as non-existent and listed it as an example of plaintiff's fabricated authority (footnote 9). || Fabricated: Case Law | Court identified this citation as non-existent and listed it as an example of plaintiff's fabricated authority (footnote 9). || Misrepresented: Case Law | Court noted this existing case was cited but does not support the proposition for which plaintiff offered it (footnote 10).

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

17 MAR 2026 · Court Case

Sarah & Regina Alonso v. Jackson

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.

Court: W.D. WashingtonParty: Lawyer

Harms: Hallucination in legal filings

04 MAR 2026 · Court Case

Ryan Adam Dixon v. MultiCare Health System

Misrepresented: Case Law | Plaintiff cited Bounds v. Smith to support a proposition; the Court found the case did not support the proposition offered. || Fabricated: Case Law | Plaintiff cited Mazza v. Washoe Cnty.; the Court identified this as a non-existent case cited by the plaintiff. || Fabricated: Case Law | Plaintiff cited Shirley v. Precision Castparts Corp.; the Court identified this citation as non-existent. || Fabricated: Legal Norm | Plaintiff relied on regulatory and plan citations that the Court noted do not exist as cited (plaintiff later characterized them as typographical errors). || Misrepresented: Case Law | Plaintiff cited Ecological Rights Foundation v. Pacific Lumber Co.; the Court found the case did not support the proposition for which it was offered.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

04 MAR 2026 · Court Case

Medal v. Amazon.com Services, LLC

Fabricated: Legal Norm | Plaintiffs repeatedly cited '21 U.S.C. § 343(r)(6)(D)', but that subsection does not exist; Plaintiffs' counsel admitted the citation arose from insufficiently supervised LLM use and the court called the inclusion unacceptable.

Court: W.D. WashingtonParty: LawyerTool: Unidentified

Harms: Hallucination in legal filings

03 MAR 2026 · Court Case

In the Matter of the Estate of CAROL M. CAREY

Misrepresented: Case Law | Appellant cited 'In re Estate of Stoler, 113 Wn. App. 104 (2002)'; court found this citation incorrect and corresponding to State v. Neely, 113 Wn. App. 100 (a criminal case) and thus inapplicable. || Fabricated: Case Law | Appellant cited 'Estate of Wallace v. Palmer, 103 Wn. App. 1064 (2000)', which the court noted does not appear to exist. || Fabricated: Case Law | Appellant cited 'In re Estate of Powers, 255 Ill. App. 3d 1006 (1994)', which the court found does not appear to exist. || Fabricated: Case Law | Appellant cited 'McIntosh v. McIntosh, 282 Ga. 610, 652 S.E.2d 546 (2007)', which the court indicated does not appear to exist. || Fabricated: Case Law | Appellant cited 'In re Estate of Griffith, 327 P.3d 612 (Colo. 2014)', which the court determined does not appear to exist. || Misrepresented: Case Law | Appellant cited 'Perez v. Pappas, 98 Wn.2d 835, 659 P.2d 475 (1983)', which the court found inapplicable to the estate/TEDRA issues raised.

Court: CA WashingtonParty: Pro Se Litigant

Fine: 1 USD

Harms: Hallucination in legal filings

02 MAR 2026 · Court Case

Put A Bird On It, LLC v. Seattle Arena Holdings, LLC

Fabricated: Case Law | Appellant's opening brief included AI-generated erroneous citations and false quotations—mixing fictitious captions, misattributed citations, and legal principles not supported by the cited cases; attorneys admitted the citations were produced by 'AI-based search engines' and apologized to the court.

Court: CA WashingtonParty: LawyerTool: Unidentified

Harms: Hallucination in legal filings

13 FEB 2026 · Court Case

Merz v. City of Kalama

Misrepresented: Case Law | Merz relied on Caruso v. Local Union 690, 107 Wn.2d 524, 529-30 (1987) to support a 'per se' defamation assertion; court found the citation misleading because the cited pages do not contain the 'per se' language Merz attributed to it. || Fabricated: Case Law | Merz cited 'Sorensen v. City of Bellingham, 15 Wn. App. 2d 730, 733, 478 P.3d 1110 (2020)' which was inaccurate/fabricated; Merz later admitted he intended to cite Norg v. City of Seattle, 200 Wn.2d 749 (2023); court noted the inaccuracy but declined to dismiss on that basis.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

09 FEB 2026 · Court Case

Valve Corporation v. Rothschild et al.

Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling. || Fabricated: Case Law | Defendants cited a non-existent PacTool opinion and quoted text that does not exist in the case; plaintiff's counsel states the opinion does not exist and the quoted text is fabricated. || False Quotes: Case Law | Defendants quoted language attributed to Crow Tribe that is not contained in the opinion; plaintiff notes the case exists but the quoted text is fabricated. || False Quotes: Case Law | Defendants attributed a quotation to Cordis (Fed. Cir.) that does not appear in the opinion; plaintiff identifies the quote as fabricated. || False Quotes: Case Law | Defendants quoted Bilzerian for language about expert testimony creating an "aura of authority"—plaintiff states the quoted text does not appear in Bilzerian and the proposition is unsupported by that case. || False Quotes: Case Law | Defendants partially misquoted Primiano; plaintiff notes the quoted language is incorrect and provides the correct formulation from the case. || False Quotes: Case Law | Defendants attribute an “ipse dixit” quote to Micro Chem. plaintiff says the case exists but the quoted language is not found and the case does not support Defendants' broader proposition. || Fabricated: Case Law | Defendants cited an Amazon.com v. Personal Web Technologies opinion that plaintiff reports does not exist in the W.D. Wash.; plaintiff identifies the opinion as fabricated. || Fabricated: Case Law | Defendants cited Diamondback Industries v. Repeat Precision opinion and quoted a holding that plaintiff reports does not exist; plaintiff identifies the opinion/quotation as fabricated. || Misrepresented: Case Law | Defendants cited Marx & Co. but relied on a proposition the case does not address; plaintiff notes the case exists but was misapplied. || Misrepresented: Case Law |

Court: W.D. WashingtonParty: Lawyer

Harms: Hallucination in legal filings

04 FEB 2026 · Court Case

Joann LeDoux v. Outliers, Inc.

Fabricated: Case Law | Plaintiff cited a non-existent state-court decision, "Berg v. Chevrolet Motor Div., 84 Wn.2d 102, 108, 524 P.2d 226 (1974)"; court identified this citation as nonexistent and noted the correct authority was Baughn v. Honda Motor Co. || Fabricated: Legal Norm | Plaintiff quoted text from RCW 7.72.010(2) that does not exist and altered statutory language (Dkt. 173-1 ¶ 59); court found the quoted provision nonexistent. || False Quotes: Exhibits & Submissions | Plaintiff cites a purported deposition quote from James Kababick about "post-production degradation of stimulant compounds" that does not appear in the cited transcript; court was unable to find the quote. || False Quotes: Case Law | Plaintiff quoted language attributed to United States v. Hankey to support an evidentiary proposition, but the quoted phrase does not appear in Hankey. || False Quotes: Case Law | Plaintiff included two quoted passages attributed to Fair v. King Cnty. that do not appear in the decision the brief cites; court found the quoted language absent. || False Quotes: Case Law | Plaintiff quoted language not present in In re Washington Mut. (694 F. Supp. 2d 1192 (W.D. Wash. 2009)) and in a 2011 order (2011 WL 1158387); court found the cited phrases absent and that original use was for a different proposition. || Fabricated: Doctrinal Work | Plaintiff's expert reports (Kababick and Shippee) cite multiple articles that do not exist or are misattributed (court reviewed a table of ~10 such faulty citations and found errors). || False Quotes: Case Law | Plaintiff quoted language attributed to HSS Enters. v. AMCO Ins. (2008 U.S. Dist. LEXIS 31659) that does not appear in that order (the phrase "harsh sanction" was not found).

Court: W.D. WashingtonParty: Lawyer

Harms: Hallucination in legal filings

29 JAN 2026 · Court Case

Dana Serine Greene v. GSK PLC

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.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

20 JAN 2026 · Court Case

Mitchell Taylor Button et al. v. John Jimison (2)

Fabricated: Case Law | Plaintiffs cited a Sixth Circuit case for the proposition courts may strike 'entire documents where scandalous or irrelevant matter dominates'; the court was unable to locate that case. || Fabricated: Case Law | Plaintiffs cited a case purportedly condemning efforts to label individuals as serial litigants; the court could not find the cited authority supporting that proposition. || Fabricated: Case Law | In a supplemental filing, plaintiffs cited a district court case for the proposition that a 'notice of unavailability' is not recognized in federal practice; the court was unable to locate the cited authority and the citation provided led to a different case. || Fabricated: Case Law | Plaintiffs cited two Ninth Circuit opinions for the proposition that Rule 12(b) motions must be filed before a responsive pleading; the court found the quoted language does not appear in the cited opinions and was unable to locate the authorities. || Fabricated: Case Law | Plaintiffs cited a district court case allegedly stating that striking an answer 'does not resuscitate' waived defenses; the court could not locate the cited case or quote. || Fabricated: Case Law | Plaintiffs attributed a quotation to a Ninth Circuit case claiming Rule 12(c) requires 'closed pleadings'; the court found that quote does not appear in the cited opinion.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

13 JAN 2026 · Court Case

Collins v. Nova Association Management Partners LLC

Fabricated: Case Law | Court found multiple non-existent legal citations incorporated in Plaintiff's opposition brief (Dkt. No. 53, cited on pages 5, 6, 8–10, 13) as pointed out by the moving defendants; Court ordered counsel to list and explain them. || Misrepresented: Case Law | Court noted inaccurate and inapt legal citations in the same brief (incorrect or miscited authorities); moving defendants highlighted these on reply and Court required counsel to explain how they appeared.

Court: W.D. WashingtonParty: Lawyer

Harms: Hallucination in legal filings

01 JAN 2026 · Law / Act

2026 Chatbot Legislation — Washington HB 2225 [URL: http://app.leg.wa.gov/billsummary?BillNumber=2225&Year=2025]

2026 chatbot legislation — Signed by Governor

Generative AI ·Data Privacy & Protectionapp.leg.wa.gov ↗

01 JAN 2026 · Policy / Guidance

2026 Chatbot Legislation — Washington SB 5984 [URL: https://app.leg.wa.gov/billsummary?BillNumber=5984&Year=2025]

2026 chatbot legislation — Inactive

Generative AI ·Data Privacy & Protectionapp.leg.wa.gov ↗

01 JAN 2026 · Law / Act

Washington HB 1168

Washington legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

01 JAN 2026 · Law / Act

Washington HB 1170

Washington legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

01 JAN 2026 · Law / Act

Washington HB 2503

Washington legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

22 DEC 2025 · Court Case

Levy v. Google LLC

Fabricated: Case Law | Plaintiff cited Kelley v. Conan, 555 F.3d 630, 634 (8th Cir. 2009); the court could not locate this case and found the citation appears to be nonexistent. || Fabricated: Exhibits & Submissions | Plaintiff referenced 'Exhibit X' and 'Exhibit Y' in support of asserted meetings but did not file or locate those exhibits in the record; the court found the referenced exhibits were absent. || False Quotes: Case Law | Plaintiff cited and quoted language attributed to Diaz v. Pan American World Airways, Inc. but provided an incorrect citation and the quoted language does not appear in the actual Diaz opinion; the court noted the citation error and that the case does not address pretext. || False Quotes: Case Law | Plaintiff cited Villiarimo with an incorrect citation and attributed language not found in the actual Villiarimo decision; the court flagged the miscitation and misquotation. || Fabricated: Case Law | Plaintiff cited Springer v. Boeing, 138 Wash. App. 248 (1997); the court was unable to locate the case and noted the citation does not appear in legal databases. || False Quotes: Case Law | Plaintiff cited Bahrampour v. Lampert and attributed language and an employment-law proposition not present in that decision; the court noted the quotation/language does not appear in the cited opinion.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

13 NOV 2025 · Court Case

William McNae and Ronda McNae v. ARAG Insurance Company

Fabricated: Legal Norm | Plaintiffs relied on a purported quotation from Local Civil Rule 1(c) claiming it "permits flexibility 'in the interest of justice'", but the rule contains no such language and the attribution was inaccurate. || Fabricated: Case Law | Plaintiffs attributed the quotation "factual materials underlying an ERISA determination are discoverable" to Abatie v. Alta Health & Life Ins. Co.; the Court found the quotation does not appear in Abatie and could not be located via Westlaw/Google.

Court: W.D. WashingtonParty: Pro Se Litigant

Fine: 100 USD

Harms: Hallucination in legal filings

30 OCT 2025 · Court Case

Lareina A. Sauls v. Pierce County, et al.

Misrepresented: Case Law | Plaintiff relied on United States v. Mississippi, 82 F.4th 387 (5th Cir. 2023) as supporting the proposition that disability-based sanctions/adverse inferences are irreversible; the Court stated that the cited case does not discuss or support that inference.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

17 OCT 2025 · Court Case

Mitchell Taylor Button et al. v. John Jimison (1)

False Quotes: Case Law | Plaintiffs quoted a supposed Ninth Circuit case for the phrase 'to weed out meritless suits at an early stage' but the Court could not locate the cited case or the quote in any Ninth Circuit opinion. || False Quotes: Case Law | Plaintiffs cited a Washington Court of Appeals case purportedly stating defamatory statements about private individuals 'do not become matters of public concern merely because they touch on litigation,' but the Court could not find the case or the quoted language in any Washington opinion. || False Quotes: Case Law | Plaintiffs quoted a Washington Court of Appeals case as saying UPEPA protects speech 'on issues of legitimate public debate,' but that quote does not appear in the cited opinion. || False Quotes: Case Law | Plaintiffs quoted a Tenth Circuit opinion for the proposition '[a] litigant may not manipulate procedure to gain tactical advantage,' but the Court was unable to locate the cited Tenth Circuit opinion or the quoted language. || Fabricated: Case Law | Plaintiffs cited a Southern District of California case/order for the proposition that blanket denials do not comply with Rule 8; while a case by that name exists, the Court could not locate the specific order Plaintiffs cited. || Fabricated: Case Law | Plaintiffs cited a case from this district for the proposition the Court can strike an unintelligible answer, but the Court could not locate the cited case; the case number referenced an unassigned, administratively terminated matter.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

17 OCT 2025 · Court Case

Artur Sargsyan v. Amazon.com Inc.

Fabricated: Case Law | Plaintiff cited "Board of Trustees v. RBS Group, 2008 WL 5127215;" the Court was unable to verify the case in legal databases and characterized it as made-up, warning of Rule 11 sanctions for future fake citations.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

14 OCT 2025 · Court Case

Robert Allen Reed et al. v. Community Health Care et al.

Fabricated: Case Law | Plaintiffs cited “Flores v. United States, 189 F.3d 477, 481 (9th Cir. 1999)”; the Court found this decision does not exist and identified it as part of a pattern of fictitious citations. || Fabricated: Case Law | Plaintiffs cited “Abbey v. United States, 953 F.2d 639, 642 (9th Cir. 1991)”; the Court determined this decision does not exist and characterized it as fictitious. || Fabricated: Case Law | Plaintiffs cited “Urrutia, 44 F.3d at 1265” as authority; the Court identified this citation among decisions that do not exist and treated it as fabricated. || Fabricated: Case Law | Plaintiffs relied on “State v. Kaiser, 198 Wn. App. 142 (2017)” to support a WCPA theory; the Court found no such decision exists and labeled the citation fictitious. || Fabricated: Case Law | Plaintiffs cited “Right v. Breen, 128 Wn. App. 104 (2005)” for defamation law; the Court concluded this authority does not exist and flagged it as fabricated.

Court: W.D. WashingtonParty: Pro Se LitigantTool: implied

Harms: Hallucination in legal filings

14 AUG 2025 · Court Case

Johnny McMurry, Jr. v. Neiders Company LLC, et al.

Fabricated: Case Law | Plaintiff cited a non-existent case in his briefing (Dkt. No. 17 at 6); the Court noted the citation was non-existent, admonished Plaintiff, and warned of possible Rule 11 sanctions.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

30 JUL 2025 · Court Case

Ligeri v. Amazon.com Services

Fabricated: Case Law | Plaintiff cited a C.D. Cal. case to oppose consolidation; the Court found the case does not exist and the Westlaw cite leads to a Florida state-court filing. || False Quotes: Case Law | Plaintiff attributed language to Hall v. Hall about consolidation and reassignment; the Court stated the quoted text does not appear in that opinion.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

15 MAY 2025 · Court Case

Beenshoof v. Chin

Fabricated: Case Law | Plaintiffs cited a nonexistent case; the Court could not locate it on Westlaw, Lexis, or the internet and warned that citing nonexistent authority may warrant Rule 11 sanctions.

Court: W.D. WashingtonParty: Pro Se Litigant

Harms: Hallucination in legal filings

29 MAR 2024 · Law / Act

Washington Senate Bill 5950

Provide $300,000 in 2024 and $500,000 in 2025 for Seattle to lease space for technology startups, focusing on AI, and to develop curricula for worker skills in AI as a business resource.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2fiscal.wa.gov ↗

18 MAR 2024 · Law / Act

Washington Senate Bill 5838 (2024)

Establishes a task force to assess AI use and trends, recommending guidelines and legislation. Requires examination of AI's impact on safety, privacy, and rights. Mandates reports by 2026. Defines AI-related terms. Task force expires June 30, 2027.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2lawfilesext.leg.wa.gov ↗

14 MAR 2024 · Law / Act

Washington House Bill 1999

Defines digitization to include AI use in creating or altering images. Criminalizes disclosing fabricated intimate images, with AI-defined digitization as a key factor. Establishes defenses and penalties. Provides victims legal recourse for unauthorized AI-altered image disclosures.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2lawfilesext.leg.wa.gov ↗

30 JAN 2024 · Executive Order

Washington Executive Order 24-01

Instructs WaTech to report on generative AI initiatives and develop training plans. Requires WaTech and DES to provide procurement and usage guidelines. Mandates creating an accountability framework for generative AI's ethical use. Orders assessments of AI’s impact on communities and workforce by specific deadlines.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2governor.wa.gov ↗

23 OCT 2023 · Other

City of Seattle Generative Artificial Intelligence Policy

Regulates City departments' acquisition and use of generative AI, requiring Seattle IT to approve exceptions and conduct risk reviews. Mandates human review of AI outputs, attribution, and bias reduction. Prohibits AI training using City data without controls.

seattle.gov ↗

23 JUL 2023 · Law / Act

Washington Senate Bill 5152

Defines "synthetic media" in political campaigns as manipulated media creating false impressions. Permits candidates to seek legal relief against such media use. Requires disclosure of manipulation. Holds sponsors liable, not media, unless disclosure is altered. Encourages prompt court rulings.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2lawfilesext.leg.wa.gov ↗

25 JUL 2021 · Other

Washington (2022) SB 5460

Amends autonomous vehicle testing regulations, requiring self-certifying entities to provide contact information, testing locations, vehicle identification, insurance proof, accident reports, and notify law enforcement. Permits public access to testing information and annual legislative reports. Effectively defines "autonomous" vehicles. Effective October 1, 2022.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+7app.leg.wa.gov ↗

18 MAY 2021 · Other

Washington SB 5092 (2021-22), Section 151

Requires the office of the chief information officer to convene a work group to examine review and audit of automated decision systems for fairness, transparency, and accountability. Develops recommendations for state law changes on AI-enabled system use and procurement.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2lawfilesext.leg.wa.gov ↗

22 MAR 2018 · Other

Washington (2018) HB 2970

Establishes a work group to develop policy recommendations for autonomous vehicle operation on Washington roads. Requires following industry developments, exploring legal changes, and engaging stakeholders. Mandates annual progress reports and recommendations for state laws and policies. Expires December 31, 2023.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+7app.leg.wa.gov ↗