Courts on AI / Fabricated or misquoted citations
Tekoma Chaney v. Transdev Services Inc. et al.
United States District Court for the Central District of California · Federal district courts · CA · · No. 2:24-cv-10761-ODW-AJR · opinion
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
- The court fined counsel $2,500 and required reporting the sanction order to other courts where counsel had appeared.
- Recorded conduct
- Counsel filed a submission with three fabricated case citations, including In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015) after using LexisNexis+ (Protégé). — 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.
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