Collins v. Nova Association Management Partners LLC
U.S. District Court, Western District of Washington · W.D. Wash. · Washington bar guidance
Verified May 14, 2026
- Citation
- Collins v. Nova Ass'n Mgmt. Partners LLC, No. 2:20-cv-01206 (W.D. Wash. Jan. 13, 2026)
- Decided
- January 13, 2026
Summary
The court identified multiple non-existent legal citations spanning pages 5-13 of plaintiff's opposition brief, along with misrepresentations of real cases. The pattern of fabricated and misquoted authority was consistent with unverified generative AI output. The court ordered plaintiff's counsel to show cause why sanctions should not issue for filing the brief without verifying the citations.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to Show Cause issued requiring plaintiff's counsel to explain in writing why sanctions should not be imposed. Counsel was directed to inform the client of the order. No monetary penalty had been assessed as of the order's entry; the show cause process governs further sanctions.
Why does Collins v. Nova Association Management Partners LLC matter for law firms using AI?
For a managing partner, the Collins OSC illustrates that a single opposition brief carrying fabricated authority across nine pages is enough to trigger a Rule 11 show cause posture in federal court, independent of whether the underlying claim has merit. The exposure does not require an adversary’s motion: the court raised the issue sua sponte after spotting the citation defects on review. Firms that allow associates or contract attorneys to file dispositive briefs without a verified-citation step are accepting that risk on every filing.
Sources
Primary sources
Further reading
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
- https://www.damiencharlotin.com/hallucinations/
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.