Sauls v. Pierce County
U.S. District Court, Western District of Washington · W.D. Wash. · Washington bar guidance
Conduct
Pro se plaintiff cited a Fifth Circuit decision that did not support the proposition for which it was offered.
Consequence
TRO denied on multiple grounds. No sanction imposed; footnote warning that future hallucinated cites may lead to sanctions.
Lesson
A reasonable-judge default is now to add an AI-citation footnote to any order against a pro se litigant whose citations do not check out.
Verified May 7, 2026
- Citation
- Sauls v. Pierce County, No. 3:25-cv-05957-TMC (W.D. Wash. Oct. 30, 2025) (Cartwright, J.)
- Decided
- October 30, 2025
Summary
Pro se plaintiff Lareina A. Sauls filed an emergency motion for a temporary restraining order against Pierce County, judges and officers of Pierce County Superior Court, and two private attorneys, seeking to block a state-court CR 11 sanctions hearing. Among the merits problems Judge Tiffany M. Cartwright identified, plaintiff cited a Fifth Circuit decision (82 F.4th 387 (5th Cir. 2023)) that the court found did not support the proposition for which it was offered. The court appended a footnote noting it has no formal rule against the use of generative AI to write pleadings or briefs but reminding the plaintiff that Rule 11(b)(2) applies to any pleading regardless of whether AI assisted in drafting it.
- AI tool:
- Generative AI inferred from the citation pattern; specific tool not identified on the record
What sanction did the court impose?
Court denied the TRO motion on multiple grounds, including failure to show likelihood of success on the merits and failure to satisfy the ex parte requirements of Rule 65(b)(1). No sanction imposed. The footnote is a prospective warning that future filings citing authority that does not exist may lead to court-imposed sanctions, citing Saxena v. Martinez-Hernandez, 2025 WL 1194003 (D. Nev. Apr. 23, 2025).
Why does Sauls v. Pierce County matter for law firms using AI?
Sauls is the first of two W.D. Wash. orders from Judge Cartwright addressing AI-style citation reliability in late 2025 and early 2026 (the second is Greene v. GSK PLC, Jan. 29, 2026, also captured in this database). The Sauls footnote articulates a posture that is becoming the default for federal judges in the Pacific Northwest: AI use itself is not a Rule 11 violation, but Rule 11(b)(2) still requires that legal contentions be warranted by existing law, and a litigant who lets AI invent or misquote authority has signed a paper that fails that standard. The judge does not need to find the litigant intended to deceive; the misrepresentation is enough.
For firm-level intake, the more interesting fact is the routinization. Cartwright did not write a separate order or a published opinion about AI; she added a paragraph to a TRO denial that would have looked the same a year earlier without it. That suggests judges are now treating these warnings as boilerplate footnotes attached to any order against a litigant whose citations did not check out, the same way they once cited Twombly automatically when discussing motion-to-dismiss standards. Firms briefing motions in this district should expect a similar footnote in any order where opposing counsel’s citation reliability is even partially at issue, and should plan their citation-checking workflows accordingly.
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.
- Judges in W.D. Wash. are normalizing footnote-level AI warnings as a routine addendum rather than a special finding; do not assume a footnote means the court has no further concerns.
- Cartwright's framing (no formal rule against AI use, but Rule 11 still applies) is a clean articulation for any internal AI policy memo: AI use is not the violation; misrepresenting the contents of authority is.
- When the same judge issues multiple warnings against parties who continue to file unverified cites, the next firm to appear in front of that judge inherits the heightened expectations; chambers patterns travel.