Parker v. Costco Wholesale Corp.
The case
Myeesha Parker v. Costco Wholesale Corp., United States District Court for the Western District of Washington, November 7, 2025, No. 2:25-cv-00519-SKV, Doc. 60 (Order Imposing Sanctions). Magistrate Judge S. Kate Vaughan. Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-82-parker-v-costco.pdf. Source URL: https://websitedc.s3.amazonaws.com/documents/Parker_v._Costco_USA_7_November_2025.pdf
What happened
Attorney Oscar E. Desper III filed three papers containing hallucinated case and record citations and legal errors consistent with unverified generative AI use, including at least four quotations attributed to real cases that do not contain the quoted language and citations to inapplicable authorities. The court found Desper certified the filings under Rule 11 knowing he had not verified the authority, conduct it deemed tantamount to bad faith. Note: the candidate metadata's August 28 date and $6,200 figure are incorrect; the sanctions order issued November 7, 2025.
The rule and the sanction
The court found Rule 11 violations and violations of the Washington Rules of Professional Conduct. It publicly reprimanded Desper and referred him to the Chief Judge for an ethical inquiry and further discipline; ordered him to pay $3,000 to the court within fourteen days; ordered him to compensate Costco for the expenses of responding to his motion to strike (the parties later agreed the amount at $3,220.50, payable by January 9, 2026, per the December 8, 2025 joint notice, Doc. 70: https://storage.courtlistener.com/recap/gov.uscourts.wawd.346252/gov.uscourts.wawd.346252.70.0.pdf); and ordered him to provide a copy of the sanctions order to his client immediately.
How it could have been avoided
Verify every quotation against the original source before filing; altered quotes without brackets or ellipses misrepresent the record. When delegating drafting to a contract attorney, the signing lawyer must still review all authority, since Rule 11 duties are non-delegable.