A quarter of the citations in filed briefs are Westlaw or Lexis ids. We list them, we do not guess.Coverage ›

Replays · D. Wyo. · February 24, 2025

Wadsworth v. Walmart Inc.

In a suit against Walmart and Jetson Electric Bikes, the plaintiffs' motions in limine cited nine cases. The court could find only one of them. All eight it could not find were cited by Westlaw number, which makes this replay a test of what an open register can and cannot tell you.

Court
U.S. District Court for the District of Wyoming
Decision
Order on Sanctions and Other Disciplinary Action, February 24, 2025 (ECF 181), 17 pages. Reported at 348 F.R.D. 489.
Docket
No. 2:23-CV-118-KHR
The filing
The plaintiffs' motions in limine (ECF 141, January 22, 2025), filed a few weeks before trial.
Sanctioned
Three of the plaintiffs' lawyers: the one who drafted the motions, and two who signed them.
Sanction, in the court's words
The drafting lawyer "is hereby sanctioned a penalty of $3,000 and shall pay the amount into the Registry of this Court within fourteen days of this Order." (Order on Sanctions and Other Disciplinary Action, p. 17) His admission to practice in the case was revoked. The two lawyers who signed were fined $1,000 each.
AI tool, as the decision states it
An in-house database the order calls "the AI platform" (the order says the lawyers did not use ChatGPT) (Order on Sanctions and Other Disciplinary Action, p. 4)
Public record
Order on Sanctions and Other Disciplinary Action, February 24, 2025 (ECF 181); Order to Show Cause, February 6, 2025 (ECF 156); the case on CourtListener.

What the court found

"The problem with these cases is that none exist, except United States v. Caraway, 534 F.3d 1290 (10th Cir. 2008)." (Order to Show Cause, p. 2)

"The cases are not identifiable by their Westlaw cite, and the Court cannot locate the District of Wyoming cases by their case name in its local Electronic Court Filing System." (Order to Show Cause, p. 2)

Each citation the court listed

as filedwhat the court saidwhat the register holds at this citationour default check today
1Wyoming v. U.S. Department of Energy, 2006 WL 3801910 (D. Wyo. 2006)"The cases are not identifiable by their Westlaw cite" (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
2Holland v. Keller, 2018 WL 2446162 (D. Wyo. 2018)"The cases are not identifiable by their Westlaw cite" (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
3United States v. Hargrove, 2019 WL 2516279 (D. Wyo. 2019)"a real estate secondary source appears for United States v. Hargrove, 2019 WL 2516279 (D. Wyo. 2019)." (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
4Meyer v. City of Cheyenne, 2017 WL 3461055 (D. Wyo. 2017)"The cases are not identifiable by their Westlaw cite" (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
5U.S. v. Caraway, 534 F.3d 1290 (10th Cir. 2008)The court found this case exists; it is the one exception to "none exist". (Order to Show Cause, p. 2)United States v. Caraway (10th Cir. 2008)Found Found: United States v. Caraway (10th Cir. 2008)
6Benson v. State of Wyoming, 2010 WL 4683851 (D. Wyo. 2010)"Benson v. State of Wyoming, 2010 WL 4683851 (D. Wyo. 2010) refers to Quilter v. Holder, 401 Fed. App'x 985 (5th Cir. 2010)." (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
7Smith v. United States, 2011 WL 2160468 (D. Wyo. 2011)"Smith v. United States, 2011 WL 2160468 (D. Wyo. 2011) leads to a Supreme Court of the Australian Capital Territory case." (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
8Woods v. BNSF Railway Co., 2016 WL 165971 (D. Wyo. 2016)"An apparent United States Securities and Exchange Commission filing matches with Woods v. BNSF Railway Co., 2016 WL 165971 (D. Wyo. 2016)." (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it
9Fitzgerald v. City of New York, 2018 WL 3037217 (S.D.N.Y. 2018)"The cases are not identifiable by their Westlaw cite" (Order to Show Cause, p. 2)A Westlaw number, not a page. No open register holds these.Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it

9 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 8 Cannot verify, 1 Found. Each citation was pasted as a line of text (the quoted words first, where we have them) and checked the way the checker checks a draft: no language model, nothing stored. The register column is a direct lookup of the volume and page.

What a check before filing would have shown

No red rows. The report would have listed the eight Westlaw numbers together as "cannot verify" and found Caraway. That is an honest answer and not enough on its own: the court found the problem by looking each number up on Westlaw, and a lawyer holding this report would have had to do the same.

What this page does not show

  • No open register can resolve a Westlaw number, ours included. On filed briefs, about a quarter of all citations are Westlaw or Lexis numbers (see Measurements).
  • Whether a case is still good law. This is not a citator.
  • Anything about the lawyers beyond what the court wrote.

Check your own draft

Paste the draft or upload the PDF. The default check reads every case citation and returns rows like the ones above in a few seconds, with no language model and nothing stored. It is free to try without an account. Then read what the court would read: every case you cite, at the page you cite.

Check a draft before you fileAll replays

Published September 24, 2026, updated September 24, 2026. We read the decision and copied the court's list; if we have misread it, write to hello@proofread.law. The rows are from the run dated above; they can change when the checker does.