Courts on AI / Fabricated or misquoted citations

O.K., LLC v. Melka

Court of Appeal of the State of California, Second Appellate District, Division Five · State appellate courts · CA · 2026-04-23 · No. B341146; Super. Ct. No. LC103261 · opinion

Fabricated or misquoted citations

The California Court of Appeal, Second District on 2026-04-23 affirmed the judgment, awarded appellate costs to O.K., and rejected record-augmentation arguments tied to alleged fabricated citations in O.K., LLC v. Melka. The self-represented party filed a reply brief with one fabricated case citation and one mischaracterized case citation.

Disposition: The motion to augment the record was denied, the judgment was affirmed, and O.K. was awarded ordinary costs on appeal.
Recorded conduct: Melka’s opening brief cited several cases that respondent said either did not exist or did not support the propositions asserted; the court reported respondent’s view that this was a hallmark of AI-generated legal citations but imposed no consequence for the citations. — outcome: noted, no consequence; 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.

’s respondent’s brief highlights the deficits in the appellate record and asks this court to affirm on that basis. The respondent’s brief also complains that several of the cases cited by Melka in her opening brief either do not exist or do not support the claimed proposition for which they were cited— hallmarks, in respondent’s view, of use of an artificial intelligence tool to generate legal citations. The respondent’s brief also endeavors to rebut Melka’s arguments on the merits, insofar as permitted by the state of the record. Melka responded by filing a reply brief and a motion to augment the appellate record. Her motion seeks to augment the record with two items: O.

Court document: courts.ca.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 at www.courts.ca.gov; quoted passage confirmed. Re-coded from the document 2026-09-08 (independent second read).

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