Courts on AI / Fabricated or misquoted citations
Ashcraft v. First-Citizens Bank and Trust Company
United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 851435 · No. 2:26-cv-02251-JLS (JDEx) · order
On 2026-03-25, U.S. District Court for the Central District of California denied the motion for discovery sanctions and advised that false citations in future briefs may result in sanctions. A self-represented party submitted a complaint with The complaint cited a nonexistent Plantronics decision while seeking discovery sanctions.
- Disposition
- The court denied plaintiff's sanctions motion and advised him that false citations may result in sanctions.
- Recorded conduct
- Plaintiff cited GN Netcom, Inc. v. Plantronics with a case number, date, and Westlaw citation that did not match any located decision. — outcome: warning; 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.
apply. properly served with process. See Fed. R. Civ. P. 4(b), (c) (1). Absent such service, the Court lacks personal jurisdiction over Defendants and Plaintiff may not seek sanctions against *2 Courts may deny discovery motions for failure to comply such unserved parties. with the Local Rules' requirements for such motions. See Pina v. Lewis, 717 F. App'x 739, 740 (9th Cir. 2018) (district Nonetheless, even assuming Defendants were properly served court may properly deny a motion to compel “for failing to with a proper summons and the Complaint on March 13, comply with local rules”); see also Tri-Valley CARES v. U.S. 2026, Defendants would not have been subject to this Court's Dep't of Energy, 671 F.3d 1113, 1131 (9th Cir. 2012) (“Denial rules of procedure before that time. Thus, again assuming a of a motion as the result of a failure to comply with local proper service of process had been effected on March 13, rules is well within a district court's discretion.”); Lumber 2026, the earliest Plaintiff could have sent a compliant L.R. Liquidators, Inc. v. Sullivan, 2012 WL 4464867, at *4 (C.D. 37-1 meet and confer letter
Authorities cited in the passage: Inc. v. Sullivan, 2012 WL 4464867