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Courts on AI / Fabricated or misquoted citations

Gregoire v. Board of Trustees of SF BART

United States District Court for the Northern District of California · Federal district courts · CA · · No. 3:25-cv-02150-TSH · order

The Northern District of California on 2026-05-06 fined counsel $1,000, ordered live CLE, and required service of the order on the client and the California State Bar in Gregoire v. Board of Trustees of SF BART. Counsel filed an opposition with one fabricated case citation.

Disposition
The court fined counsel $1,000, ordered live CLE, and required service of the order on the client and the California State Bar.
Recorded conduct
Counsel filed an opposition with one fabricated case citation. — outcome: fine; actor: lawyer; $1,000
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.

After reviewing Plaintiff’s opposition, the Court was unable to locate three of the four cases cited therein. 1 Concerned that these inaccuracies suggest hallucinations from the use of The Court does not include the names of these cases here, as doing so could inadvertently amplify any error that these cases exist. United States District Court Northern District of California generative artificial intelligence tools, the Court issued a second show cause order, directing Ms. Barsotti to file a declaration by May 4, 2026 that: (1) identifies, verbatim and by page and line, each statement or quotation in the opposition that cites to a legal authority; (2) explains the origin of each such statement and citation, including whether any generative artificial intelligence tool was used in preparing any portion of the filing, and, if so, which tool(s) and how they were used;

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