Courts on AI / Fabricated or misquoted citations
Samuel K. v. Winsley Focia
California Court of Appeal · State appellate courts · CA · · 2026 WL 539183 · No. No. 24STRO08015) · opinion
California Court of Appeal on 2026-02-26 in Samuel K. v. Winsley Focia found the self-represented party's opening brief contained three citation defects, including Medical Board v. Superior Court and People v. Panah, involving nonexistent authorities, fabricated or misattributed quotations. The court dismissed the appeal, assessed appellate costs, and addressed the defective authorities.
- Disposition
- The court dismissed the appeal, assessed appellate costs, and addressed the defective authorities.
- Recorded conduct
- The self-represented party's opening brief contained three citation defects, including Medical Board v. Superior Court and People v. Panah, involving nonexistent authorities, fabricated or misattributed quotations. — outcome: costs order; 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.
authorities necessarily dooms her appeal. (Id. at p. 436.) v. Frederickson (2020) 8 Cal.5th 963, 1000 [“Self-represented [parties] are ‘held to the same standard of knowledge of law In total, Focia's opening brief contains 12 quotations, 11 and procedure as is an attorney[.]’ ”]; Rappleyea v. Campbell of which are fabrications. Several of these fake quotations (1994) 8 Cal.4th 975, 985 [“A doctrine generally requiring are attributed to nonexistent cases. For example, Focia cites or permitting exceptional treatment of parties who represent Medical Board v. Superior Court (2022) 88 Cal.App.5th 459, themselves would lead to a quagmire in the trial courts, and 475 (Medical Board) for the propositions that “ ‘[i]n high- would be unfair to the other parties to litigation.”].) stakes civil hearings, due process requires confrontation of the actual evidence[ ]’ ”; “ ‘[i]n liberty-depriving hearings, “[E]xtensive reliance on nonexistent legal authority ... due process requires advisement of the dangers of self- justif[ies] striking appellant's opening brief or dismissing the representation[ ]’ ”; and “ ‘[c]ross-examination of adverse appeal. [Citations.]” 3 (Noland, supra, 114 Cal.App.5th at p. witnesses is constitutionally required in high-stakes civil 436.) Because Focia's opening brief relies almost completely proceedings.’ ” (Bolding omitted.) No case titled “Medical on fabricated and inapposite legal authority, we dismiss her Board v. Superior Court” was published in 2022; the appeal. reporter citations given by Focia correspond to two inapposite criminal cases published the following year (People v. Venable (2023) 88 Cal.App.5th 445, People v. Sedano (2023) DISPOSITION 88 Cal.App.5th 474); and the above quotations do not appear in any case, published or nonpublished. “Medical Board,” and The appeal is dismissed. Focia to bear her own costs on the quotes taken from it, appear to be “AI ‘hallucinations[.]’ appeal. ” (Noland, supra, 114 Cal.App.5th at p. 431.) Furthermore, Focia's “brief[ ] [is] peppered with inaccurate NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS citations that do not support the propositions for which they are cited.” (Noland, supra, 114 Cal.App.5th at p. 436.) In one instance, Focia cites People v. Panah (2005) 35 Cal.4th 395, We concur: 475, as holding that “ ‘[a]dmitting a transcript without the original recording is reversible error.’ ” (Bolding omitted.) CHAVEZ, Acting P. J.
Authorities cited in the passage: Medical Board v. Superior Court (2022) 88 Cal.App.5th 459, 475 · hallucinations · Admitting a transcript without the original recording is reversible error · peppered with inaccurate citations · Opening brief cited a nonexistent case 'Medical Board v. Superior Court · Brief quoted 'Admitting a transcript without the original recording is reversible error.' and cited People v. Panah · Rappleyea v. Campbell of which are fabrications. Several of these fake quotations · Focia cites or permitting exceptional treatment of parties who represent Medical Board v. Superior Court · Board v. Superior Court · People v. Venable · People v. Sedano · Focia cites People v. Panah