Courts on AI / Fabricated or misquoted citations

Tekoma Chaney v. Transdev Services Inc.

United States District Court for the Central District of California · Federal district courts · CA · 2026-04-28 · No. 2:24-cv-10761-ODW (AJRx) · order

Fabricated or misquoted citationsLexisNexis+ Protégé

The Central District of California on 2026-04-28 fined counsel $2,500 and required reporting the sanction order to other courts where counsel had appeared in Tekoma Chaney v. Transdev Services Inc. et al. Counsel filed a submission with three fabricated case citations, including In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015).

Disposition: Summary judgment was granted and Chaney’s counsel was sanctioned $2,500 payable to the Court, with declaration-notice requirements.
Recorded conduct: Counsel Gavril Gabriel used LexisNexis+ Protégé to draft portions of the opposition and used fabricated In re Shubert authority three times without verification. The court imposed a $2,500 court sanction. — outcome: fine; actor: lawyer; $2,500
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.

2d 1391, 1393 (1980) (quoting Roadway Express, 447 U. S. at 767). Two overarching factors drive the Court’s sanctions order. First, the imposition of sanctions for submitting generative-AI hallucinations is so well-documented at this point that the Court finds the failure to verify citations after using generative-AI rises to the level of bad faith. According to one source, in the United States alone, there have been 915 legal opinions addressing the improper use of generative-AI in the last three years. See Damien Carlotin, AI Hallucination Cases, https://www. damiencharlotin. com/hallucinations/ (last visited Apr. 26, 2026). Courts in this District have begun ordering heavy sanctions against attorneys caught using fabricated cases generated by AI.

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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