June 1, 2026 (in 3 days): New York: 22 NYCRR Part 161 takes effect, system-wide AI policy for all UCS courts

Medal v. Amazon.com Services LLC

U.S. District Court, Western District of Washington · W.D. Wash. · Washington bar guidance

Court sanction

Verified April 26, 2026

Citation
Medal v. Amazon.com Services LLC, No. 2:23-cv-01975-JHC, Dkt. 129 (W.D. Wash. Mar. 4, 2026)
Decided
March 4, 2026

Summary

Plaintiffs' counsel filed an Opposition to Amazon's Motion to Stay (Dkt. 122) containing "juxtaposed" language paired with a false citation to a nonexistent statutory provision. Amazon moved for an Order to Show Cause. Judge John H. Chun granted the motion and ordered plaintiffs' counsel to explain each signatory's role in the false citation, whether and how generative AI aided the drafting or research, and what verification mechanisms were in place.

AI tool:
Unspecified generative AI
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

Order to Show Cause granted. Plaintiffs' counsel directed to file a written explanation on or before March 18, 2026. No monetary sanction imposed in this order; potential sanctions deferred pending the response.

Why does Medal v. Amazon.com Services LLC matter for law firms using AI?

Medal illustrates the now-routine OSC posture: when opposing counsel surfaces a fabricated citation, the court does not sanction reflexively but compels counsel to disclose AI use and verification practices on the record. For managing partners, the operative lesson is that a written, file-level verification protocol is what counsel will be asked to produce, often within two weeks, and its absence is itself a finding.

Sources

Primary sources

Further reading

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.