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Courts on AI / Fabricated or misquoted citations

Juan Villalovos-Gutierrez, et al. v. Gerard Van de Pol, et al. (2)

United States District Court for the Eastern District of California · Federal district courts · CA · · No. Case 2:24-cv-02305-DJC-CKD · memorandum opinion

Eastern District of California on 2026-02-24 in Juan Villalovos-Gutierrez, et al. v. Gerard Van de Pol, et al. (2) found counsel's motion contained two citation defects involving nonexistent authorities. 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 motion contained two citation defects involving nonexistent authorities. — 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.

20 respond to the troubling assertion that defendant has produced improperly redacted records. 21 Defendant also cites cases purportedly from this district that do not exist, 1 even though defendant 22 was issued a prior warning in this case that doing so is a potential ground for sanctions. (See ECF 23 No. 29 at 5-6.) 24 The undersigned reserves ruling on the request for attorney fees for plaintiffs’ initial 25 motion to compel, subject to plaintiffs filing a properly noticed and supported motion for 26 1 These case citations provided by defendant, and possibly others, are inaccurate and/or the cases 27 do not exist: Brown v. Johnson, No. 1:06-cv-01068, 2009 WL 1788406 (E.D. Cal. June 23, 2009); Watkins v. Cal. Dep’t of Corr. & Rehab., No. 1:08-cv-01530, 2012 WL 1906523, at *1 28 (E.D. Cal. May 25, 2012). (See ECF No. 36 at 13.) 4 Case 2:24-cv-02305-DJC-CKD Document 39 Filed 02/24/26 Page 5 of 5 1 sanctions with evidence to substantiate the request. In addition, defendant and/or defendant’s

Authorities cited in the passage: Brown v. Johnson, No. 1:06-cv-01068, 2009 WL 1788406 · Watkins v. Cal. Dep’t of Corr. & Rehab., No. 1:08-cv-01530, 2012 WL 1906523

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