Courts on AI / Fabricated or misquoted citations
Perez v. Schaal
Superior Court of California, County of Sacramento · State trial courts · CA · · No. 25CV019484 · order
The Sacramento Superior Court rules on a demurrer and addresses Joseph Perez’s unsupported quotation from Adorh Farms. The court says the quotation does not appear in that opinion or any reported case, flags possible generative AI use, declines sanctions, and warns future fabricated authority may be sanctioned.
- Disposition
- The court ruled on the demurrer and warned the self-represented plaintiff to verify all citations and quotations.
- Recorded conduct
- Self-represented plaintiff attributed a quotation about waiver of demurrer to Adorh Farms, but the court could not find it in that or any reported case. — outcome: warning; 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.
Plaintiff quotes Adorh Farms, Co. v. Love (1967) 255 Cal.App.2d 366 at p. 371: “The filing of an answer … effected a waiver of the right to demur.” (Opp., at p. 8: 19–21.) This is at best an incomplete statement of law. “A party objecting to a complaint or cross-complaint may demur and answer at the same time.” (Code Civ. Proc., § 430.30, subd. (c); see § 472a, subd. (a) [“A demurrer is not waived by an answer filed at the same time.”].) More importantly, although the Adorh Farms opinion exists,[3] it does not contain the quoted language. Nor can the court find the quoted language in any other case reported in California or elsewhere. This quotation may be the result of irresponsible use of generative artificial intelligence (“AI”). ... The Court declines to begin the process of imposing sanctions at this time but strongly cautions Plaintiff to take better care in making only good-faith, well-researched, legally sound arguments in future. All citations and quotations submitted to the Court must be verified. Future submissions of fabricated authority may result in sanctions.
Authorities cited in the passage: Adorh Farms, Co. v. Love, 255 Cal.App.2d 366 (1967) · Code Civ. Proc. § 430.30 · Code Civ. Proc. § 472a · Noland v. Land of the Free, L.P., 114 Cal.App.5th 426 (2025) · Hopkins & Carley v. Gens, 200 Cal.App.4th 1401 (2011)
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