Greene v. GSK PLC
U.S. District Court, Western District of Washington · W.D. Wash. · Washington bar guidance
Conduct
Pro se plaintiff filed a motion for court-assisted Hague service containing false citations that the Court characterized as bearing 'the emblems' of generative AI use.
Consequence
Motion denied on substantive Article 3 grounds; Rule 11 AI warning issued in the order, with sanctions reserved for any future filing that cites authority that does not actually exist.
Lesson
W.D. Wash. judges are converging on a no-formal-rule-but-Rule-11-still-applies framing, with first-occurrence AI conduct met by a warning paired with a substantive denial.
Verified May 10, 2026
- Citation
- Greene v. GSK PLC, No. 3:25-cv-05357-TMC, Order (W.D. Wash. Jan. 29, 2026) (Cartwright, J.), ECF No. 18
- Decided
- January 29, 2026
Summary
Pro se plaintiff Dana Serine Greene filed a product-liability action against GSK PLC alleging complications from Paxil taken during childhood. After unsuccessful attempts to effect international Hague service on GSK at its UK headquarters, Greene filed a 'motion to compel clerk to execute USM-94 and return completed Hague service packet,' which the Court construed as a motion requesting court-assisted service under Fed. R. Civ. P. 4(c)(3). Greene's motion included false citations that the Court identified as bearing 'the emblems of the use of a generative artificial intelligence tool,' which the Court noted 'can fabricate or hallucinate legal precedent' (quoting Romero v. Goldman Sachs Bank USA, No. 1:25-CV-2857-GHW, 2025 WL 1916119, at *1 (S.D.N.Y. June 25, 2025)).
- AI tool:
- Unspecified generative AI
- Sanction amount:
- None (warning only; the Court reserved Rule 11 sanctions for any future filing providing 'authority to the Court that does not actually exist')
What sanction did the court impose?
Judge Tiffany M. Cartwright denied the motion for court-assisted service on substantive Article 3 grounds (Greene had not yet submitted a service packet that complied with the Hague Service Convention's Article 3 requirements). On the AI conduct, the Court applied the W.D. Wash. no-formal-rule framing and issued a Rule 11 warning rather than imposing sanctions: 'The Court has no formal rule against the use of generative artificial intelligence to write pleadings and briefs. To the extent she uses these tools, the Court reminds Ms. Greene that she remains bound by Federal Rule of Civil Procedure 11, which requires that by presenting a motion or other written paper to the Court, a party certifies that its legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law. In the future, Ms. Greene may be sanctioned for providing authority to the Court that does not actually exist.' The Court cited Saxena v. Martinez-Hernandez, No. 2:22-cv-02126-CDS-BNW, 2025 WL 1194003, at *2 n.5 (D. Nev. Apr. 23, 2025) (collecting cases) as cross-circuit authority for warning pro se litigants about generative AI hallucinations. Greene was advised that she could obtain assistance from any non-party adult over 18 to sign and submit the service packet to the UK Central Authority.
Why does Greene v. GSK PLC matter for law firms using AI?
The cross-citation pattern in this order is doctrinally interesting. Cartwright cites Romero v. Goldman Sachs Bank USA (S.D.N.Y. June 25, 2025) for the ‘emblems of the use of a generative artificial intelligence tool’ framing, and Saxena v. Martinez-Hernandez (D. Nev. Apr. 23, 2025) for the collecting-cases authority on pro se AI warnings. The result is a Rule-11-anchored AI policy framed in language a sister-district judge can quote without revisiting first principles. The 2025 to 2026 W.D. Wash. corpus is functionally a federation of judge-level applications of this template: Settle in Dixon v. MultiCare (Mar. 4, 2026) used the same ‘no formal rule, but Rule 11 applies’ phrasing in nearly identical terms.
For partners reading the case as defense-side precedent or as a model for chambers responses, the operational point is that Cartwright did not adjudicate the AI conduct as a separate sanctions matter. The denial of the motion is grounded in Article 3 of the Hague Service Convention; the AI warning is layered on top as a Rule 11 caution to Greene about future filings. That sequencing is now visible across multiple districts (D. Conn. Ambrose v. Lee, D.N.J. Doe v. United States, Bankr. D. Colo. CHP 1010 McDowell v. Turpen, W.D. Wash. Dixon, W.D. Wash. Greene) and is the dominant federal response to first-occurrence pro se AI hallucination in early 2026.
The cross-Cartwright pattern (Sauls v. Pierce County, Oct 30, 2025, plus Greene, Jan 29, 2026) is also worth noting for firms tracking chambers-level AI policy: when the same judge applies the no-formal-rule template across multiple cases, it functions as an unwritten chambers practice, even absent a formal standing order. Defense counsel against pro se litigants in W.D. Wash. can rely on this pattern in deciding whether to ask for fees, an admonishment, or filing preconditions.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Track Cartwright's repeat use of the W.D. Wash. no-formal-rule framing: Greene is the second order in this database where Cartwright has applied this template (after Sauls v. Pierce County, Oct 30, 2025), suggesting it is becoming her chambers practice for first-occurrence AI conduct by pro se litigants.
- Document the 'emblems of the use of a generative artificial intelligence tool' framing borrowed from Romero v. Goldman Sachs Bank USA (S.D.N.Y. June 25, 2025); this cross-district quotation provides a useful evidentiary shorthand for the citation pattern that triggers AI suspicion.
- Note that Cartwright denied the motion on independent substantive grounds (Article 3 service-packet defects) before reaching the AI conduct, then folded the AI warning into the same order. This is the same procedural shape as Doe v. United States (D.N.J.) and Dixon v. MultiCare (W.D. Wash.): dismiss / deny on independent grounds, add AI warning, reserve fees for future.
- Cross-reference the W.D. Wash. cluster: Settle (Dixon), Cartwright (Greene, Sauls), plus the absence of a court-wide chambers AI standing order means the operative rule in W.D. Wash. is judge-specific application of Rule 11 rather than a district-wide policy.