Courts on AI / Fabricated or misquoted citations
Geddes v. LoanCare, LLC
United States District Court for the Eastern District of California · Federal district courts · CA · · 2026 WL 1092496 · No. No. 2:25-cv-02955-DMC · order
The Eastern District of California on 2026-04-22 fined counsel $1,000 and referred counsel to the State Bar after finding false quotations in the remand papers in Krista C. Geddes v. LoanCare, LLC, et al. Counsel filed a submission with two false case quotations.
- Disposition
- The court imposed $1,000 in sanctions, ordered Geddes to serve the order on the California Bar Association and file proof of compliance, and otherwise addressed the jurisdiction briefing misconduct.
- Recorded conduct
- Geddes, a licensed attorney proceeding pro se, manufactured two significant quotes in jurisdictional supplemental briefing: a Kachlon quotation and a Barrionuevo quotation, neither of which appeared in or matched the cited opinions. — outcome: regulatory referral; actor: lawyer; $1,000
- 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.
However, the undersigned finds that while the scope of the violation here may be distinguishable from Tercero, the existence of an intent to gain an unfair advantage through a misrepresentation of legal citation is the same in both cases, and here warrants both a monetary sanction and reporting to the bar. Although its use is not conclusive here, this Court expresses its grave concern about the use of generative artificial intelligence without the appropriate due diligence and verificationbytheattorneysigningthefiling. Theappearance of hallucinated cases, improper citations, and distortions of opinions create consequences that fall on the attorney, as filing documents with this Court certifies that any assertions made are supported by law and signatures on the documents filed mean the attorney has performed the appropriate due diligence. If Plaintiff elects to go down the treacherous path of employing generative artificial intelligence in drafting her filings to this Court, she must realize she bears the responsibility for that election and all related consequences, and nothing about that election constitutes a substitute for attorney diligence.