Incident Tracker / United States (federal)
That Xiong v. Minga Wofford
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
- 2026-05-21
- Who used the AI
- Lawyer
- AI tool
- ChatGPT
- Conduct
- 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.
- Outcome
- Other
- 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
- 2026-09-07
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Johnson v. Dunn, No. 2:21-cv-01701-AMM (N.D. Ala.), 792 F. Supp. 3d 12412025-07-23 · US District Court, Northern District of Alabama (Southern Division) · SanctionsIn the Northern District of Alabama, Judge Anna M. Manasco publicly reprimanded Butler Snow attorneys Matthew B. Reeves, William J. Cranford and William R. Lunsford for filing two motions containing citations hallucinat…
- Mata v Avianca, Inc.2023-06-22 · US District Court, Southern District of New York · SanctionsThe origin case of legal AI hallucination sanctions: two New York attorneys were fined $5,000 after citing six ChatGPT-invented cases in a personal-injury filing and persisting after the fabrications were questioned, pr…
- In re Brian E. Mitchell, USPTO Proceeding No. D2026-162026-07-27 · US Patent and Trademark Office, Office of Enrollment and Discipline · OtherThe US Patent and Trademark Office's Office of Enrollment and Discipline publicly reprimanded California patent attorney Brian Mitchell, whose AI-drafted claim-construction chart in a federal patent case cited nonexiste…
- United States v. Cohen, No. 18-CR-602 (JMF) (S.D.N.Y.)2024-03-20 · US District Court, Southern District of New York · OtherIn the US District Court for the Southern District of New York, Judge Jesse M. Furman declined to sanction attorney David M. Schwartz, who filed a motion for Michael Cohen citing three non-existent cases that Cohen had…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “That Xiong v. Minga Wofford”, safelegalai.com/tracker/that-xiong-v-minga-wofford (accessed 2026-09-08). Data: CC BY 4.0.