Courts on AI / Fabricated or misquoted citations
Dotson v. Bob Evans Farms, LLC
United States District Court for the Central District of California · Federal district courts · CA · · No. 2:25-cv-11993-MWC-DSR · order
The Central District of California denies Michael Dotson’s reconsideration application and identifies three quotations misattributed to Mission Power. The court says the language appears in Horne instead, describes the errors as AI-hallucination hallmarks, and orders counsel to show cause about sanctions and bar referral.
- Disposition
- The court denied reconsideration and ordered plaintiff's counsel to show cause about monetary sanctions and a state bar referral.
- Recorded conduct
- Plaintiff’s counsel repeatedly attributed quoted language to Mission Power that the court found in a different case, Horne v. Wells Fargo. — outcome: pending; 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.
At three different points in his Application, Plaintiff attributes quoted language to Mission Power, 883 F. Supp. at 492, which appears nowhere in the body of the cited case. See Appl. at 7:10–7:15, 10:5–10:8, 10:17–10:22. The discrepancies between the quoted language and the language of the cited case are so significant as to abrogate any assumption that the misattributions are the result of typographical error. Plaintiff’s repeated inclusion of quotations misattributed to Mission Power, which are present in the language of an entirely different case, 1 “bear the hallmarks of hallucinated cases created by artificial intelligence (‘AI’) tools.” Cummins v. Becerra, No. 1:25-CV-01853-DC-AC, 2026 WL 373336, at *1 (E.D. Cal. Feb. 10, 2026) ... Accordingly, the Court SETS an ORDER TO SHOW CAUSE Re: Monetary Sanctions and State Bar Referral of Todd M. Friedman for breach of the duty of candor to the Court.
Authorities cited in the passage: Mission Power Engineering Co. v. Continental Casualty Co., 883 F. Supp. 488 (C.D. Cal. 1995) · Horne v. Wells Fargo Bank, N.A., 969 F. Supp. 2d 1203 (C.D. Cal. 2013) · Cummins v. Becerra, 2026 WL 373336 (E.D. Cal. Feb. 10, 2026) · Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)