Courts on AI / Fabricated or misquoted citations
Modern Floor Specialists, Inc. v. City of Los Angeles
United States District Court for the Central District of California · Federal district courts · CA · · No. 2:25-cv-04765-ODW (JPRx) · order
On 2026-04-03, U.S. District Court for the Central District of California granted the city defendants’ motion to dismiss and ordered counsel to file a declaration or show cause regarding the potentially hallucinated Mabee citation. Counsel submitted a filing with fabricated or nonexistent authorities, including Mabee v. County of Orange and Cochran v. City of Wichita.
- Disposition
- The court granted City Defendants’ motion to dismiss, denied plaintiffs’ sanctions motion, deferred City Defendants’ sanctions motion for hearing, and ordered counsel Matic to show cause about the Mabee citation.
- Recorded conduct
- Plaintiffs’ counsel Joshua Matic cited supposed Ninth Circuit case Mabee v. County of Orange; the reporter citation led to unrelated Tenth Circuit case Cochran v. City of Wichita and the court found no such Mabee case. — 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.
In Plaintiffs’ opposition brief to City Defendants’ Motion to Dismiss, Matic cites to a supposed Ninth Circuit opinion in Mabee v. County of Orange, 784 F. App’x 585, 588 (9th Cir. 2019). ... the Court finds no case in any federal or state jurisdiction with the case caption Mabee v. County of Orange. ... If Matic cannot demonstrate that Mabee exists, Matic shall SHOW CAUSE why the Court should not sanction him for using artificial intelligence to perform legal research and failing to perform a reasonable inquiry into whether his legal citations are supported.