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 · 2026-02-12 · 2026 WL 395737 · No. 2:25-cv-09673-BFM · memorandum opinion

Fabricated or misquoted citations

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.

In reviewing the Plaintiff's filings, the Court identified four citations offered by Plaintiff in its Reply that do not exist. At the hearing on the Motion, the Court asked Mr. Charnley about the nonexistent citations and whether he or anyone at his firm used generative AI to assist with drafting its papers. Mr. Charnley stated that he wrote the brief, that he did not use generative AI in preparing the brief, and that he was not aware that anyone in his firm used such technology. ... The hallucinated citations wasted the Court's limited resources.

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

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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