Courts on AI / Fabricated or misquoted citations
Doe 1, et al. v. Shirley Lai, et al.
United States District Court for the Central District of California · Federal district courts · CA · · No. Case 5:25-cv-03485-JGB-DTB · memorandum opinion
Central District of California on 2026-02-17 found defense counsel attributed a quotation to Headley that the court could not locate and cited Dann for a proposition the court could not find. The court denied the motion to dismiss, granted judicial notice, and ordered defense counsel to produce authorities or explain why sanctions should not issue.
- Disposition
- The court denied the motion to dismiss, granted judicial notice, and ordered defense counsel to produce authorities or explain why sanctions should not issue.
- Recorded conduct
- Defense counsel attributed a quotation to Headley that the court could not locate and cited Dann for a proposition the court could not find. — outcome: sanctions; actor: lawyer
- 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.
United States v. Dann, 652 F.3d 1160 (9th Cir. 2011) containing and highlighting all stated principles of law as cited in the Motion no later than 12:00 p.m., Pacific Standard Time, on February 19, 2026. IT IS FURTHERED ORDERED that, if he is unable to do so, Cabanday shall file with the Court an explanation in writing how the quotation and citations were included in the Motion and why he should not be sanctioned pursuant to (1) Rule 11(b), (c); (2) 28 U.S.C. § 1927; and (3) the inherent power of the Court to order sanctions for citing non-existent quotations and legal principles to the Court no later than 12:00 p.m., Pacific Standard Time, on February 19, 2026. IT IS FURTHER ORDERED that the written submission due on February 19, 2026, shall take the form of a sworn declaration. IT IS FURTHER ORDERED that, should Cabanday have witnesses, their statements shall also be submitted in the form of a sworn declaration and filed by February 19, 2026. IT IS FURTHER ORDERED that the Court reserves the right to call a hearing for this matter based on the evidence received. III. FACTUAL ALLEGATONS
Authorities cited in the passage: Rule 11(b)