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Incident Tracker / United States (federal)

Full Standard Properties v. SJ 6070, No. 5:25-cv-09451 (N.D. Cal.)

·US District Court for the Northern District of California·US-FEDCosts order

In the US District Court for the Northern District of California, Judge Freeman discharged an order to show cause against plaintiff's counsel who had cited nonexistent cases, after counsel reimbursed USD 14,500 in fees the fabricated citations had caused the opposing party. The court's overall fee award in the matter was USD 85,980.70.

Court
US District Court for the Northern District of California
Date
2026-08-20
Who used the AI
Lawyer
AI tool
Not identified in the record
Conduct
Plaintiff's counsel cited nonexistent cases in filings. Before the show-cause hearing counsel had reimbursed USD 14,500 in attorney's fees that the fabricated citations caused the opposing party to incur; the order to show cause was then discharged. The court's total fee award in the matter was USD 85,980.70.
Outcome
Costs order
Penalty
US$14,500
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • Multiple citations to nonexistent cases in Plaintiff's ECF 18 opposition — the court did not identify the case names
  • Pin citations to real cases in Plaintiff's ECF 18 opposition — pages were not in the cited case or discussed issues unrelated to Defendant's fee motion

What the court said

“Plaintiff filed a brief containing multiple citations to nonexistent cases.”
US District Court for the Northern District of California, ECF 30 at 1
“Where the opposition brief identifies cases that do exist, the pin citations are to pages that are not contained within the case or that discuss issues having no bearing on Defendant’s motion.”
US District Court for the Northern District of California, ECF 30 at 1
“The parties have resolved that issue informally, and Plaintiff’s counsel has reimbursed Defendant for attorneys’ fees in the amount of $14,500.”
US District Court for the Northern District of California, ECF 41 at 4
“The Order to Show Cause issued on May 21, 2026 (ECF 30) is DISCHARGED.”
US District Court for the Northern District of California, ECF 41 at 10

Timeline

  1. Plaintiff filed the state-court action over the foreclosure.
  2. Court ordered plaintiff's counsel to show cause over nonexistent cases in the fee opposition.
  3. Counsel's written response to the show-cause order was due.
  4. Court discharged the show-cause order after counsel reimbursed $14,500.
  5. Court awarded defendant $85,980.70 in fees, subject to the $14,500 setoff.

Why this case matters

Full Standard is a sanctions-light federal record. Unlike Capital Standard v U.S. Bank, the court did not publish the fabricated authorities or refer counsel after the reimbursement. The order still shows a practical cost path: counsel who caused an opponent to research nonexistent authorities paid the opponent's response costs before sanctions were decided, and the show-cause order was discharged. That makes it useful alongside Mata v Avianca because the remedy targeted wasted fee-briefing work rather than punishing the client or changing the merits outcome. The case also shows why public records may undercount hallucination details when the parties resolve sanctions informally.

Practice note

When an opponent moves for fees, every cited case and pin cite in the response should be checked against the reporter page before filing. If false authorities are discovered after filing, counsel should disclose them, reimburse costs caused by the error where appropriate, and replace the filing with verified citations before a show-cause hearing.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Full Standard Properties v. SJ 6070, No. 5:25-cv-09451 (N.D. Cal.)”, safelegalai.com/tracker/full-standard-properties-v-sj-6070 (accessed 2026-10-07). Data: CC BY 4.0.

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