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Courts on AI / Fabricated or misquoted citations

Anthony C. Hill v. Workday, Inc.

United States District Court for the Northern District of California · Federal district courts · CA · · No. 23-cv-06558-PHK · order

Fabricated or misquoted citationsCoCounsel

The Northern District of California on 2026-04-28 admonished counsel, fined counsel $1,001, required four hours of live CLE, and ordered circulation of the sanction order in Anthony C. Hill v. Workday, Inc. Counsel filed a submission with one fabricated case citation and one mischaracterized case citation.

Disposition
Attorney Webb was admonished and sanctioned with circulation, CLE, certifications, and a $1,001 personal payment to the Clerk.
Recorded conduct
Plaintiff’s counsel submitted a discovery letter brief with nonexistent South Pointe Wholesale authority and a misrepresentation of Mir v. L-3; the fake citation was caused in part by use of Westlaw’s CoCounsel AI tool and lack of supervision. The court sanctioned supervising attorney Webb. — outcome: fine; actor: lawyer; $1,001
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.

Long before the public launch of various AI or large language models such as ChatGPT, the Fifth Circuit affirmed an award of sanctions by noting that “[f]iling mountainous piles of unorganized documents and citing to nonexistent rules of law are precisely the sort of conduct that, under the objective test of Rule 11, could lead a district court to conclude that the attorney had not made reasonable inquiry into the law or was seeking to harass or delay. ” Willy, 855 F. 2d at 1172. Sanctioning a party for citing to nonexistent law is, unfortunately, not merely a product of AIhallucinated citations. See, e. g. , Dobson v. U.

Authorities cited in the passage: Dobson v. U. · Fed. R. Civ. P. 11

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