Washburn v. Houston
Arizona Court of Appeals, Division One · Ariz. Ct. App. · Arizona bar guidance
Verified April 26, 2026
- Citation
- Washburn v. Houston, No. 1 CA-CV 24-0315 FC (Ariz. Ct. App. Jan. 2, 2026) (mem. decision)
- Decided
- January 2, 2026
Summary
Carrie M. Wilcox, counsel for petitioner/appellant Christian Washburn, filed an opening brief that misrepresented five Arizona appellate decisions (Buencamino v. Noftsinger, Woyton v. Ward, Reid v. Reid, Vincent v. Nelson, and Thompson v. Thompson) as addressing specific A.R.S. section 25-408(I) relocation factors none of them actually discuss, and included fabricated quotations attributed to Owen v. Blackhawk along with quotes from the amended decree and hearing transcripts that did not appear in the cited records. Judge Cynthia J. Bailey, joined by Presiding Judge Jennifer M. Perkins and Vice Chief Judge David D. Weinzweig, observed that the misidentified caselaw and hallucinated record cites all conveniently supported Father's position.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The Court of Appeals affirmed the underlying relocation rulings and forwarded the decision to the State Bar of Arizona to review whether counsel violated any rules of professional conduct, citing the duty of candor under Ariz. R. Sup. Ct. 42, ER 3.3 and Ariz. R. Civ. P. 11(a). No monetary sanction was imposed; both parties' fee requests were denied, and Mother was awarded taxable costs on appeal.
Why does Washburn v. Houston matter for law firms using AI?
Washburn illustrates how AI-style citation errors are migrating from federal trial dockets into state appellate practice and family law, where the audience is a three-judge panel that reads every cited case. The court did not impose a monetary sanction but referred counsel to the State Bar, which for a sole practitioner is the more consequential outcome. For managing partners, the case is a reminder that brief-checking workflows belong in appellate and domestic relations practice groups, not just in litigation departments handling federal motions.
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.