Courts on AI / Fabricated or misquoted citations

Nguy v. Jabil Inc.

United States District Court for the Northern District of California · Federal district courts · CA · 2026-04-07 · No. Case No. 24-cv-06798-EKL (VKD) · order

Fabricated or misquoted citations

On 2026-04-07, U.S. District Court for the Northern District of California declined to sanction counsel after a corrected brief was filed, but warned all parties to verify the existence and accuracy of cited authorities. Counsel submitted an opposition brief with fabricated or nonexistent authorities.

Disposition: The court granted in part and denied in part Jabil’s deposition-sanctions motion, set supplemental briefing on fees and costs, and denied Jabil’s request to sanction Nguy’s counsel for the fictitious citation.
Recorded conduct: Attorney Elnaz Masoom’s original opposition to a sanctions motion contained one purported Eastern District of California case cited several times; Jabil called it fictitious and likely AI-generated, and Masoom filed a corrected opposition that removed all case citations. — outcome: warning; actor: lawyer
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.

of the bar of this Court to “comply with the standards of professional conduct required of members of the State Bar of California.” Civil L.R. 11-4(a)(1). Under California Rule of Professional Conduct 3.3, lawyers have a duty of candor, which prohibits a lawyer from “knowingly mak[ing] a false statement of fact or law to a tribunal[.]” On this record, the Court is concerned that Mr. Nguy’s counsel may have relied on AI to identify legal authorities and did not exercise care in ensuring that that fictitious AI-generated legal authorities were not included in Mr. Nguy’s opposition filed with the Court. However, Ms. Masoom promptly corrected the claimed erroneous filing, and, at the motion hearing, she confirmed that she and her firm have taken steps to ensure that this situation does not occur again. The Court therefore declines to impose any sanctions. However, all parties are reminded that the failure to confirm or double-check the accuracy, veracity, or even existence of a case or legal citation (or assertion of fact), whether created by an AI tool or otherwise, is grounds for potential sanctions. United States District Court III. CONCLUSION For the

Court document: govinfo.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 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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