Courts on AI / Fabricated or misquoted citations
Colbert v. County of Riverside
United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 931542 · No. 5:25-cv-01655-SP · memorandum opinion
On 2026-03-31, U.S. District Court for the Central District of California admonished counsel after finding a false statutory quotation and no supporting case, federal or state, for the quoted language. Counsel submitted an opposition brief with multiple nonexistent or misstated legal provisions, false quotations and fabricated or nonexistent authorities, including Mata v. Avianca, Inc.
- Disposition
- The court granted the motion to dismiss, dismissed state-law claims without leave to amend and federal civil-rights claims with leave to amend, and cautioned counsel about submitting non-existent authority.
- Recorded conduct
- Plaintiff's opposition quoted purported language from California Government Code § 845.4 that the court could not locate in that section, any other California Government Code section, or any federal or state case. — outcome: warning; 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.
Compl. ¶¶ 13-20. Plaintiff's Opposition includes a quotation of purported language from § 845.4 (Opp. at 5); however, the court could not locate the quoted statutory language in § 845.4 or any other section of the California Government Code. Nor could the court find any case, federal or state, containing the quoted language. This suggests counsel may have used artificial intelligence to draft the opposition memorandum and failed to confirm the accuracy of the citations and quotes. All counsel who appear before this court must comply with the California Rules of Professional Conduct and Federal Rules of Civil Procedure and, among other things, not make false statements of fact or law. See, e.g., Cal. R. Prof. Conduct 3.3(a)(1); Fed. R. Civ. P. 11(b)(2). Although this court has not yet enacted rules or orders specifically addressing the use of artificial intelligence, this does not permit counsel to submit a brief with non-existent authority. Cf. Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023) (“A fake opinion is not ‘existing law’ and ... [a]n attempt to persuade court or oppose an adversary by relying on fake opinions is an
Authorities cited in the passage: Fed. R. Civ. P. 11(b)(2)