| Court - Judge Name |
Effective Date |
Applicable To | Categories |
Summary |
| E.D. Wash. – Judge Stan Bastian | 11/20/2025 | Generative AI | Generative AI Usage | In Dam v. Waldron (In re Giga Watt Inc.), No. 2:25-CV-00077-SAB, 2025 U.S. Dist. LEXIS 228861 (E.D. Wash. Nov. 20, 2025), the court ruled on the parties’ various appellate motions in a bankruptcy proceeding. Appellee asked the court to issue an order for the pro se appellant to show cause why he should not be sanctioned on the grounds that the appellant made misrepresentations and “submitted fabricated legal theory generated by [GenAI].” The court concluded that in light of the appellant’s pro se status, because the court previously dismissed the action in appellee’s favor, and because there were no allegations that that “cases were completely fabricated or otherwise ‘hallucinated’ by AI,” sanctions were not warranted, and the court denied appellee’s motion. |
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Wash. – Judge Tiffany M. Cartwright | 10/30/2025 | Generative AI | Generative AI Usage | In Sauls v. Pierce Cnty., 2025 U.S. Dist. LEXIS 214447 (W.D. Wash. Oct. 30, 2025), the pro se plaintiff’s motion for a temporary restraining order cited a real case for a proposition that “does not discuss or support such an inference.” Although the court does not prohibit use of GenAI to draft a pleading or brief, Judge Cartwright warned that if the plaintiff uses GenAI tools, she must ensure that she complies with Rule 11 and does not “provid[e] authority to the Court that does not actually exist.” |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Wash -- Judge David G. Estudillo | 10/17/2025 | Generative AI | Generative AI Usage | In Button v. Jimison, 2025 U.S. Dist. LEXIS 205291 (W.D. Wash. Oct. 17, 2025), the defendant, in his response to pro se plaintiffs’ motion to strike his answer, identified that plaintiffs’ motion included hallucinated quotes and cases. In response the court warned plaintiffs that “they are responsible for verifying that all information and all citations submitted are accurate and real pursuant to Federal Rule of Civil Procedure 11,” recommended that plaintiff “should not rely on [AI] programs to conduct research or draft legal arguments, and ordered that all of plaintiffs’ future filings include a signed certification that states “I have reviewed each court decision cited in this filing. I certify that each decision cited is a valid decision and that any language quoted from a decision that is included in this filing is accurate.” The court further warned that if any of plaintiffs’ future pleadings do not include the certification, they will be stricken. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Parties | ||||
| W.D. Wash. -- Judge David G. Estudillo | 10/14/2025 | Generative AI | Generative AI Usage | In Reed v. Community Health Care, No. 3:25-cv-05228-DGE, Dkt. No. 36 (W.D. Wa. Oct. 14, 2025), in addition to dismissing one of the plaintiff’s complaints without prejudice for failing to seek leave to amend, the court briefly addressed the plaintiffs’ “continued use of fictitious case law” in various filings. Judge Estudillo ordered the plaintiffs to include a signed certification at the end of each future filing confirming their review of “each court decision cited in this filing” and that “each decision cited is a valid decision that does exist.” Any filing without this certification will be struck from the record, and any future citations to false case law will result in an order to show cause for sanctions. |
| Applies to AI Used for Filings/Drafting | ||||
| Court-Imposed Consequences – Attorneys/Law Firms | ||||
| W.D. Wash. -- Judge John H. Chun | 5/15/2025 | Generative AI | Generative AI Usage | In Benshoof v. Chin, 2025 LEXIS 93326 (W.D. Wash. May 15, 2025), the Court, in a footnote, states that it was unable to locate a case cited by the plaintiffs. Although not holding that the plaintiffs in fact used Gen AI, the Court reminded plaintiffs “that filing and signing a motion that cites to nonexistent authority can be grounds for sanctions under [Fed. R. Civ. P. 11(b)(2)],” citing cases addressing the misuse of Gen AI tools by pro se litigants. |
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting | ||||
| W.D. Wash. -- Judge Benjamin H. Settle | 2/25/2025 | Any AI | Any AI Usage | In Merz v. Kalama, 2025 WL 606160 (W.D. Wash. Feb. 25, 2025), the court admonished the pro se plaintiff’s reliance on an AI tool’s “legal advice” that led him to not file a timely motion for an extension of time to respond to the defendants’ motion for judgment on the pleadings. Although the court noted that it was “unclear whether [the plaintiff] [was] asserting this artificial legal advice as an excuse for not complying with Rule 15, or whether he [was] contending that AI confirmed that Rule 15 does not apply,” it emphasized that, regardless, “a pro se plaintiff is not immune from the rules of civil procedure.” The court did not sanction the plaintiff, but interpreted the plaintiff’s decision not to respond to the defendants’ motion as “an admission that the [defendants’ 12(c)] motion had merit.” The court granted the defendants’ motion and dismissed the plaintiff’s claims without prejudice. Despite the plaintiff’s error, the court ultimately permitted the plaintiff to file an amended complaint in order to remedy the “deficiencies” outlined by the court.
|
| Suggests Cautious Use of AI | ||||
| Applies to AI Used for Filings/Drafting |
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