District Court, W.D. Washington, 30 April 2026 to 2 June 2026. What the court wrote about citations that did not exist, in its own words, from 3 documents on file.
Retrieved · the text below was read from the source documents on that day.
What the court wrote
The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 23, 2 June 2026 · source · PDF · 5 pages
Docket text. ORDER ON SANCTIONS. The Court therefore ORDERS the following sanction for violation of Federal Rule of Civil Procedure 11(b): 1. Attorney Julian Mansoor Daman is personally sanctioned in the amount of $1,000. Within 21 days of the date of this order, Daman shall pay this sanction to the Clerk of the Court. The case number and a copy of this order should be included with payment. 2. The order to show cause issued on April 30, 2026 (Dkt. 12 ) is hereby discharged. Signed by District Judge Tiffany M. Cartwright. (BKP) (cc: WAWD Finance)
Neither case supported this assertion. The quoted text Petitioner included did not exist. In both cases, the petitioners were detained for longer than six months, meaning that their detention was no longer presumptively reasonable under Zadvydas.
The Court thus ordered Petitioner’s counsel to file a sworn declaration and: (1) account for all incorrect, misleading, or nonexistent citations and all incorrect or misleading assertions submitted to this Court; (2) provide a thorough explanation ORDER ON SANCTIONS - for how the incorrect citations discussed in this order were found or generated; and (3) to the extent that they used any artificial intelligence programs in preparing the submissions discussed in this order or any other submissions to this Court, Plaintiff’s counsel shall include the names of those programs in their declaration(s).
Id. ¶ 5. The program “fabricated the quotes and confidently presented this information as binding Ninth Circuit precedent.” Id. ¶ 6. Counsel further states that his interns “failed to mention this to [him], and have since been released from [his] employ.” Id.
120, 125 (1989). By signing Petitioner’s briefs, counsel—rather than his interns or the artificial intelligence program they used—“confidently presented” fabricated quotes to this Court . “[I]t is of no consequence whether [counsel] used AI to draft the brief because ‘[c]iting nonexistent case law or misrepresenting the holdings of a case is making a false statement to a court,’ regardless of whether generative AI suggested the content.” Oneto v.
1990)). Sanctions for fabricated citations may include “(1) monetary sanctions, (2) striking the filing containing erroneous citations, (3) requiring written notification to the client, (4) requiring written notification to judges incorrectly identified as having authored nonexistent cases, and (5) referring attorneys to the appropriate disciplinary body for disciplinary proceedings.” Id. Courts addressing similar misconduct have issued fines between $1,000 and $5,000.
Docket entry 21, 1 June 2026 · source · PDF · 6 pages
Docket text. ORDER GRANTING PETITION FOR WRIT OF HABEAS CORPUS. Respondents are ORDERED to release Petitioner Fadi El Bitar from custody within ONE day of this Order. Counsel for Respondents shall submit a status report to the Court by the end of the day on June 2, 2026 confirming Petitioner's release. Signed by District Judge Tiffany M. Cartwright. (BKP)
10 at 3. As discussed in this Court’s order to show cause, the cited cases do not support Petitioner’s assertion and the quoted text appears to be hallucinations fabricated by an artificial intelligence program. Dkt.
Docket entry 12, 30 April 2026 · source · PDF · 4 pages
Docket text. ORDER TO SHOW CAUSE. The Court ORDERS Petitioner's counsel to SHOW CAUSE by May 21, 2026 why they should not be sanctioned pursuant to Rule 11. Signed by District Judge Tiffany M. Cartwright. (BKP)
ORDER TO SHOW CAUSE - The written submission shall take the form of a sworn declaration. Plaintiff’s counsel shall (1) account for all incorrect, misleading, or nonexistent citations and all incorrect or misleading assertions submitted to this Court; (2) provide a thorough explanation for how the incorrect citations discussed in this order were found or generated; and (3) to the extent that they used any artificial intelligence programs in preparing the submissions discussed in this order or any other submissions to this Court, Plaintiff’s counsel shall include the names of those programs in their declaration(s). Dated this 30th day of April, 2026. a Tiffany M.
What the text mentions
Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.
Tools namedGemini / Bard
MentionsRule 11
Mentionssanctions
Mentionsan order to show cause
Mentionsstriking a filing
Dollar figures near "sanction", "fine", "pay" or "fees"$1,000, $2,500, $5,000
Where this fits
This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.