Courts on AI / Fabricated or misquoted citations
In re Hakhverdyan
United States Bankruptcy Court for the Central District of California · Federal bankruptcy courts · CA · · No. 1:25-bk-11049-VK · memorandum opinion
United States Bankruptcy Court for the Central District of California on 2026-03-03 in In re Lusine Hakhverdyan found counsel's motion cited Whittaker v. Otto, 2014 WL 37845 (9th Cir.), which the court described as inaccurate or nonexistent. The court denied the debtor's Rule 60 motions after noting an inaccurate or nonexistent Whittaker citation in the debtor's papers.
- Disposition
- The court denied the debtor's motions and requests for sanctions, noting inaccurate or nonexistent citations only in a footnote.
- Recorded conduct
- The debtor occasionally used inaccurate or nonexistent case citations, including Whittaker v. Otto and In re Chionis with wrong or inapposite citations. — outcome: noted, no consequence; actor: litigant in person
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
21 3. FRCP 60(b)(4) – Orders Void for Lack of Jurisdiction 22 23 Under FRCP 60(b)(4), a judgement or order may be set aside as void for lack of 24 2 25 In these motions, Debtor occasionally refers to inaccurate or nonexistent case citations. For example, in the First Relief Motion, Debtor cites “Whittaker v. Otto, 2014 WL 37845 (9th Cir.),” with the description “Counsel lacks Probation and Parole, 83 A.3d 293 (Commonwealth Court of Pennsylvania 2014), which does not discuss the 27 authority of counsel. Also in the First Relief Motion, Debtor cites to “In re Chionis, 531 B.R. 52 (coercive litigation threats violate bankruptcy protection.)” Chionis is not in 531 B.R. 52; it is an unpublished decision of the Ninth 28 Circuit Bankruptcy Appellate Panel which can be found at In re Chionis, 2013 WL 6840485 (9th Cir. BAP December 27, 2013) (concerning action for violation of discharge injunction; this decision is inapposite to Debtor’s FRCP 60 Motions). -16-
Authorities cited in the passage: Whittaker v. Otto, 2014 WL 37845 (9th Cir.) · In re Chionis, 531 B.R. 52 · Whittaker v. Otto, 2014 WL 37845 · B.R. 52
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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