The sanctions record · United States District Court, Western District of Washington, 2026
King v. AT&T Corp.
Jtwain King v. AT&T Corp., et al., Case No. 2:25-cv-02270-LK · Order Imposing Sanctions, Document 75 · District Judge Lauren King · filed 13 October 2026
Order read in full, three pages; every quotation is from it. Source: the order as filed, obtained as a PDF from the AI Hallucination Cases document store.
A sworn statement on every filing, and on every letter. A self-represented plaintiff cited nonexistent cases in her opposition to a motion for judgment on the pleadings. She called them “citation verification errors”. The court did not find that credible, found a Rule 11 violation, and ordered her to include, in all future filings and all future correspondence with opposing counsel, including discovery responses, a statement under penalty of perjury on whether generative AI was used, naming the tool, and certifying personal review and that every citation and quotation refers to existing authority.
The record
- CourtUnited States District Court, Western District of Washington, at Seattle
- JudgeLauren King, United States District Judge
- CaseNo. 2:25-cv-02270-LK. The nonexistent cases were in the plaintiff’s opposition to Equifax’s motion for judgment on the pleadings
- Date13 October 2026, after an order to show cause of 9 September 2026
- SanctionedThe plaintiff, Jtwain King, who represents herself
- ToolNot admitted. She said no generative AI tool was used to draft any filing. The court had observed that “these errors are hallmarks of nonexistent cases created through artificial intelligence”
- ConsideredDismissal with prejudice, the attorney’s fees Equifax incurred in responding to the hallucinated citations, and the sworn statement
- OrderedThe sworn statement, on all future filings and all future correspondence with opposing counsel, including discovery responses
- Not orderedNo fee award, because she committed to “comply with the Court’s directives” going forward. Her remaining claims were not dismissed, and the stay was lifted
- AuthorityFederal Rule of Civil Procedure 11, citing Malkeet Lnu v. Blanche, 177 F.4th 1014, 1032 (9th Cir. 2026)
What the court ordered
The court took her at her word on the facts in her complaint and kept her claims alive. It did not accept her account of the citations:
“However, the Court does not find her assertions that the hallucinated cases were merely ‘citation verification errors’ to be credible.”
It then made the order that travels. From now on, each filing and each letter to opposing counsel must carry a statement under penalty of perjury:
“addressing whether generative AI was used, disclosing the name of the tool used, and certifying that she has personally reviewed the correspondence or filing and that all citations and quotations therein refer to existing authority, and any factual assertions therein are supported by adequate foundation (e.g., personal knowledge or evidentiary support).”
The court warned that it may impose sanctions, “up to and including dismissal”, for any future violation.
Why it matters
Two features travel. First, the duty reaches beyond the court file. Standing orders have asked for an AI certification on filings; this order extends a sworn statement to correspondence with the other side, discovery responses included.
Second, the statement is specific. It is not a yes or no on AI. It names the tool, and it certifies personal review of every citation, every quotation and the foundation for every factual assertion, document by document.
The lesson for the next filing
An order like this one asks for the same three facts on every document: whether AI was used, which tool, and who personally checked it. A record made at the time of each document is what lets that statement be given, and shown, without reconstruction.
Regulayer™ creates checkable evidence of who approved exact words and when: which AI was used, what a named person reviewed, and the document it was sealed to, made at the time and verifiable free by the court without trusting the person who made it. It does not do the checking. It shows that the checking happened, and who stood behind it.
Sources
- King v. AT&T Corp., No. 2:25-cv-02270-LK (W.D. Wash. Oct. 13, 2026), Order Imposing Sanctions, Dkt. 75, three pages, read in full for this page
Related
- The full sanctions record
- LNU v. Blanche, the Ninth Circuit decision this order cites
- Judge Michael L. Brown, N.D. Georgia, an AI certification on every filing
Checked against the order, read in full. Information, not legal advice.
Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.