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Courts on AI / Fabricated or misquoted citations

TQJ, LLC v. Jennifer Esquivel et al.

United States District Court for the Central District of California · Federal district courts · CA · · 2026 WL 395737 · No. Case No.: 2:25-cv-09673-BFM · memorandum opinion

Central District of California on 2026-02-12 in TQJ, LLC v. Jennifer Esquivel et al. found counsel's brief cited four defective authorities, including Steele v. County of San Mateo, Kogan v. Martin, and a Muller citation the court could not locate. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Disposition
The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
Recorded conduct
Counsel's brief cited four defective authorities, including Steele v. County of San Mateo, Kogan v. Martin, and a Muller citation the court could not locate. — 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.

apparently even an awareness that they were present in the what steps to take with respect to the Motion and with respect brief—is equally troubling; it suggests he did not review the to sanctions. authority cited before he filed the Reply under his signature or before he appeared to argue the Motion. IT IS SO ORDERED No later than February 19, 2026, Mr. Charnley is cc: Counsel of Record ordered to show cause why he should not be sanctioned (either monetarily, or by the striking of his pleading) Initials of Preparer: ch under Rule 11, 28 U.S.C. § 1927, or the Court's inherent include an explanation for the inclusion of nonexistent legal

Authorities cited in the passage: Steele v. County of San Mateo · Kogan v. Martin · United States v. De La Paz · Rule 11

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