Courts on AI / Fabricated or misquoted citations
Quinteros v. Harbor Distributing, LLC
Court of Appeal of California, First Appellate District · State appellate courts · CA · · No. Super. Ct. No. CGC24620226) · order
On 2026-06-11, in Quinteros v. Harbor Distributing, LLC, the California First District Court of Appeal imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar. Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.
- Disposition
- The court imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar.
- Recorded conduct
- Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support. — outcome: referral; actor: lawyer; $6,000
- 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.
adequate record on an issue requires that the issue be resolved against [appellant]”].) on Plaintiff’s multiple misrepresentations and erroneous citations of authority” that “permeate[] Plaintiff’s opposition.” On July 8, the court issued a tentative ruling granting Harbor’s motion to stay under the court’s inherent authority and the doctrine of exclusive concurrent jurisdiction and noticing in a footnote, “The court is separately issuing an Order to Show Cause re Sanctions based on [LLG’s] miscitation of cases, fabrication of quotations, and blatant misrepresentation of authority.” LLG “stipulated to” the tentative ruling.5 On July 9, the court “adopted” the tentative ruling in a court order that found LLG’s “arguments [against a stay were] unavailing in light of the controlling legal standard and the substantial factual overlap between the actions.” The court found it “undeniable that the two actions are substantially similar, involving nearly all of the same parties and claims.” “Here, eight of the nine causes of action” overlapped, “both actions [were] filed by the same plaintiff’s firm,” purportedly seeking to represent classes working “during closely overlapping time periods.” The order included the footnote noticing the separately issued order to show cause (OSC) re sanctions. The separately issued OSC re sanctions explained its basis as LLG’s opposition brief, which “contains non-existent citations, fabricated quotations, and seriously misrepresents controlling authority.” More specifically, LLG repeatedly cited and relied on two cases as authority, but, as the court noted in bold font, “Neither citation is accurate ...