Jean v. Seattle Credit Union
U.S. District Court, Western District of Washington, Seattle · W.D. Wash. · Washington bar guidance
Conduct
A pro se plaintiff's response brief cited nonexistent authority; her show-cause response listed Word and Google as the 'generative AI' she used.
Consequence
Here the court struck the brief, required a sworn AI-disclosure declaration on future filings and correspondence, and warned of severe sanctions up to dismissal for any repeat.
Lesson
In this case the court required the disclosure to name the specific tool, and said listing Word and Google search did not suffice.
Verified September 29, 2026
- Citation
- Jean v. Seattle Credit Union, No. 2:25-cv-02140-LK, Minute Order (W.D. Wash. July 15, 2026) (King, J.), ECF No. 44
- Decided
- July 15, 2026
Summary
Rebecca Jean, representing herself in a suit against Seattle Credit Union, filed a response brief (Dkt. No. 34) that cited nonexistent authority, and the court issued an order to show cause. In her response and declaration (Dkt. Nos. 41 and 42), as the minute order recounts, Jean acknowledged previous procedural violations, averred that the factual allegations in her amended complaint were not the product of generative AI, and committed to abide by applicable law and verify that all citations refer to legitimate legal authority. Her show-cause response stated that she used "the following generative AI," and then listed "Microsoft Word to hand-type my response, and Google for research." The court stated that it "does not find credible Jean's explanations regarding the nonexistent authority cited in her response brief." The order also notes that Jean had failed to meaningfully meet and confer with opposing counsel on her discovery requests, and that the "redlined" second amended complaint she filed showed only deletions.
- AI tool:
- Unidentified (the order discharges a show-cause order over nonexistent authority, finds the plaintiff's explanations not credible, and requires future AI disclosure; it makes no finding that AI was used or which tool)
What did the court warn about?
By minute order entered at the direction of Judge Lauren King, the court discharged its order to show cause "with an order striking Jean's error-laden response brief." It required Jean to include, in all future correspondence with opposing counsel (including discovery responses) and in all future filings, a declaration under penalty of perjury addressing whether generative AI was used, disclosing the name of the tool, and certifying personal review and that all citations and quotations refer to existing authority and all factual assertions have adequate foundation. The court said it expects her to identify any AI tool specifically, giving as examples "CoPilot in Microsoft Word, the 'AI Overview' generated in Google searches, or Google Gemini," and warned that it "will impose severe sanctions" up to and including dismissal if it finds hallucinated cases or nonexistent quotes in future filings. It accepted the second amended complaint as operative, ordered the parties to meet and confer on discovery within 21 days and file a joint status report by August 12, 2026, and otherwise kept the case stayed. No monetary sanction was imposed.
Why does Jean v. Seattle Credit Union matter for law firms using AI?
The minute order resolves a show-cause proceeding without a monetary sanction but with a specific disclosure requirement. Judge King discharged the order to show cause, struck the response brief that contained the nonexistent authority, and directed Jean to attach a declaration under penalty of perjury to every future filing and every piece of correspondence with opposing counsel, including discovery responses. The declaration must address whether generative AI was used, name the tool, and certify personal review of citations, quotations, and factual foundation.
The order’s most practical point is its treatment of Jean’s first attempt at disclosure. Her show-cause response said she used “the following generative AI” and then listed Microsoft Word for typing and Google for research. The court held that was “not sufficient,” said it did not find her explanations for the nonexistent authority credible, and gave concrete examples of what identification looks like: CoPilot in Microsoft Word, the AI Overview in Google search results, or Google Gemini. The examples show the court reading “AI tool” to include features embedded in general-purpose software.
The order does not find that Jean used AI; it finds her account of the nonexistent citations not credible and puts a disclosure regime in place. It pairs that regime with a warning that hallucinated cases or nonexistent quotes in future filings will draw “severe sanctions,” up to and including dismissal under Rules 11(c) and 41(b).
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.
- Review how AI use is described in any court-ordered disclosure. Here the court held that naming a word processor and a search engine was not sufficient and listed CoPilot in Word, Google's AI Overview, and Gemini as examples of tools to identify.
- Consider that AI features built into everyday software may fall within a disclosure order. The court's examples included AI features embedded in Microsoft Word and Google search.
- Document the scope of a disclosure order. This one reaches correspondence with opposing counsel, including discovery responses, not only court filings.
Sources
Primary sources
- AI attribution: the order finds Jean's explanations for the nonexistent authority not credible and imposes an AI disclosure requirement, but it does not find that she used AI or identify a tool. The tracker's AI coding is a Charlotin inference.
- The order to show cause (ECF No. 39, June 16, 2026) and the stricken brief (ECF No. 34) are not in the RECAP archive and were not read; the specific nonexistent citations are not identified in this entry.