Courts on AI / Fabricated or misquoted citations
Graves v. Pacific Gas & Electric Co.
United States District Court for the Eastern District of California · Federal district courts · CA · · 2026 WL 2138081 · No. 2:25-cv-02558-DC-SCR · report and recommendation
The Eastern District of California recommends dismissing Graves’s utility-pole claims with leave to amend and denies e-filing. A footnote identifies two nonexistent California cases, notes that Pierce does not support the cited limitations point, and warns about AI research and Rule 11 sanctions.
- Disposition
- The magistrate judge recommended dismissal with leave to amend, granted leave to amend, denied e-filing, and warned Graves about nonexistent cases.
- Recorded conduct
- Self-represented plaintiff cited two nonexistent California cases and mischaracterized Pierce on limitations and continuing-violation issues. — outcome: warning; actor: litigant in person
- 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.
Plaintiff cites to Boling v. Pub. Utils. Comm'n, 105 Cal.App.3d 805 (1980) and Loving v. Cnty. of Stanislaus, 33 Cal.App.5th 444 (2019), which are not real cases. Plaintiff also cites to Pierce v. Cnty. of Orange, 526 F.3d 1190 (9th Cir. 2008), which does not discuss statute of limitations or continuing violation issues. At the hearing on these motions, the undersigned admonished Plaintiff about the danger of using Artificial Intelligence tools for legal research and writing and Plaintiff's obligation to ensure that all legal citations are legitimate. Future citations to non-existent cases may subject Plaintiff to an order to show cause as to why she should not be sanctioned under Rule 11 of the Federal Rules of Civil Procedure. ... IT IS HEREBY ORDERED that: 1. Plaintiff's motions to e-file (ECF Nos. 4 & 21) are DENIED. ... IT IS HEREBY RECOMMENDED that: 1. Defendants’ motion to dismiss (ECF No. 5) be GRANTED; 2. Plaintiff's motion for leave to amend (ECF No. 14) be GRANTED and Plaintiff allowed 21 days to file a First Amended Complaint.
Authorities cited in the passage: Boling v. Public Utilities Commission, 105 Cal.App.3d 805 (1980) · Loving v. County of Stanislaus, 33 Cal.App.5th 444 (2019) · Pierce v. County of Orange, 526 F.3d 1190 (9th Cir. 2008) · Fed. R. Civ. P. 11
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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