Courts on AI / Fabricated or misquoted citations

Gamez v. County of Fresno

United States District Court for the Eastern District of California · Federal district courts · CA · 2026-04-06 · No. 1:26-cv-00297-KES-EPG · order

Fabricated or misquoted citations

On 2026-04-06, U.S. District Court for the Eastern District of California ordered counsel to show cause why sanctions should not issue for an opposition brief with nonexistent authority, fabricated quotations, and unsupported legal assertions. Counsel submitted an opposition brief with nonexistent or misstated legal provisions, false quotations, fabricated or nonexistent authorities and mischaracterized authorities.

Disposition: The court ordered attorney Kevin Little to show cause by April 20, 2026 why he should not be sanctioned for deficiencies in the opposition brief.
Recorded conduct: Attorney Kevin Little’s opposition brief cited nonexistent cases, including Griffin, Barajas, and Holmes, fabricated a quotation from Destfino, and made unsupported legal representations. — 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.

Defendant County of Fresno’s Motion for a More Definite Statement. (ECF No. 12). It appears to the Court that Plaintiff’s brief (1) cited authority that does not exist; (2) fabricated quotes from authority that does exist; and (3) made material legal representations without supporting authority. Such issues suggest that Attorney Little relied on generative artificial intelligence (AI) to draft the opposition brief without ensuring that the generated content was accurate or otherwise supported. Accordingly, the Court issues this order directing Attorney Little to show cause why he should not be sanctioned. Dockets.Justia.com II. LEGAL STANDARDS Recently, “many courts have confronted briefs populated with fraudulent legal citations resulting from attorneys’ reliance on generative AI.” Noland v. Land of the Free, L.P., 114 Cal. App. 5th 426, 433, 446 (2025). Courts, including those in this District, have sanctioned “attorneys and pro se parties for submitting fictitious case citations, fictitious quotations, and related misrepresentations to the court.” United States v. Hayes, 763 F. Supp. 3d 1054, 1071 (E.D. Cal. 2025), reconsideration denied, No. 2:24-CR-0280-DJC, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025) (collecting cases). Sanctions have included (1) monetary sanctions; (2) the striking

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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