Courts on AI / Fabricated or misquoted citations
Kasengela v. Kaiser Foundation Hospitals
United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 2447454 · No. 2:26-cv-01666-WLH-CTS · order
The Central District of California grants Cecile Kasengela’s remand motion while addressing non-existent quotations in her self-represented briefing. The court reiterates its standing order on AI-generated hallucinated caselaw, rejects her accusation against Kaiser, and says a lawyer would face significant sanctions.
- Disposition
- The court remanded the action and admonished the self-represented plaintiff over non-existent quotations in briefing.
- Recorded conduct
- Self-represented plaintiff submitted non-existent quotations and misstated case law, then accused Kaiser of bad faith instead of correcting the citations. — 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.
Lastly, the Court underscores its Standing Order to remind Plaintiff that the inclusion of non-existent quotations in Plaintiff's briefing submitted to this Court is unacceptable. (See Opp'n at 3-4; Order Re Amended Civil Case Standing Order, Dkt. No. 65 at 18-20 (“caution[ing] that unqualified reliance on AI-generated content can result in filings that rely on misrepresentations and hallucinated, nonexistent caselaw”)). While the Court understands that Plaintiff is proceeding pro se, the Court does not condone the submission of misstated case law from any litigant and is concerned by Plaintiff's doubling-down in her Reply where she claims that Kaiser pointed out her incorrect quotations in bad faith to improperly attack her, rather than correcting her citations. ... Quoting paraphrased language generated from artificial intelligence tools, published on websites explaining case law (e.g., law.cornell.edu), or from personal manipulation without appropriate signals (e.g., without bracketing, ellipses, etc.) as if those quotations came directly from the cases themselves is squarely prohibited. If Plaintiff were a lawyer, the Court would be imposing significant sanctions for this conduct.
Authorities cited in the passage: Order Re Amended Civil Case Standing Order, Dkt. No. 65 · Chapman v. Horace Mann Property & Casualty Insurance Co., 2025 WL 3724904 (C.D. Cal. Aug. 14, 2025)