Incident Tracker / United States (federal)
Xiong v. Wofford
·United States District Court for the Eastern District of California·US-FEDWarningprovisional
On 2026-05-21, in That Xiong v. Minga Wofford, the Eastern District of California declined sanctions in light of remedial steps but required counsel to verify all future case and record citations. Counsel cited G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025) even though the court found the authority did not exist.
- Court
- United States District Court for the Eastern District of California
- Date
- 2026-05-20
- Who used the AI
- Lawyer
- AI tool
- ChatGPT
- Conduct
- Counsel Cummings and law student Herrera filed opposition/reply papers with hallucinated citations generated through ChatGPT and other generative AI. The court discharged the show-cause order and declined sanctions after their explanations.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-08
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, “Xiong v. Wofford”, safelegalai.com/tracker/that-xiong-v-minga-wofford (accessed 2026-10-07). Data: CC BY 4.0.