California · federal district court · 2025

Christopher Kluwe v. Huntington Beach Union High School District

District Court, C.D. California, 14 October 2025 to 17 October 2025. What the court wrote about citations that did not exist, in its own words, from 2 documents on file.

Case record · C.D. Cal.

  1. Court. District Court, C.D. CaliforniaCOURT
  2. Level. federal district courtLEVEL
  3. Dates. 14 October 2025 to 17 October 2025DATED
  4. Docket. No. 8:25-cv-01648DOCKET
  5. Judge. Fred W. SlaughterJUDGE
  6. Documents. 2 documents, 9 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 51, 17 October 2025 · source · PDF · 19 pages

Docket text. RESPONSE filed by Defendant Christian Eptingto Order to Show Cause,,, 46 (Attachments: # 1 Declaration of William J Becker Jr in support of response)(Becker, William) (Entered: 10/17/2025)

Cal. 2025) (imposing monetary sanctions where counsel denied using AI, refused to admit that the case was non-existent despite knowing it was non-existent, and where counsel had five opportunities to acknowledge error). In light of this guidance, we Case No.

In Hayes, the court imposed a $1,500 sanction where counsel submitted a fabricated case and quotation in a motion, then knowingly and persistently misrepresented the origin of those citations to the court.

Aug. 14, 2025), the court sanctioned counsel after the court discovered that in an “opening brief,” “well over the majority” of citations were either fictitious or misquoted. The court found a systemic failure of oversight in the firm’s brief-writing process, including reliance on AI without verification and failure to heed prior judicial warnings.

Cal. July 31, 2025), the plaintiff’s motion to remand cited a non-existent case, raising suspicion of AI use. Despite the filing’s defects and failure to disclose AI involvement as required by the court’s Standing Order, the court issued no sanctions, opting instead for an admonition and warning regarding future compliance.

Cal. July 31, 2025), counsel cited another fictitious case in support of a motion to remand. The court noted non-compliance with its AI disclosure rules but again imposed no monetary sanctions, instead cautioning that any further use of AI without disclosure would trigger further inquiry.

Jan. 22, 2025), where a motion contained multiple non-existent citations, likely AI-generated. The court declined to sanction the filer, emphasizing instead the need for future caution.

Id. (“The court cautions defendant that any further filings with citations to non-existent cases may result in sanctions”). Similarly, in Gibralter, LLC v.

Sept. 19, 2025), a court discharged an order to show cause without imposing sanctions because counsel conceded that a fictitious case reference “likely was the result of her use of AI-assisted research and drafting tools in drafting her opposition brief”, counsel acted with candor to the court admitting to using various research sources including AI, and counsel represented that she would implement “precaution to prevent future similar errors”. The court found an admonition was sufficient, and admonished counsel “to Case No.

Docket entry 46, 14 October 2025 · source · PDF · 1 pages

Docket text. (IN CHAMBERS) ORDER TO SHOW CAUSE REGARDING SANCTIONS by Judge Fred W. Slaughter: The court ORDERS Defendant Christian Epting's Counsel to show cause at an in-person hearing on Thursday, October 23, 2025, at 10:00 a.m. in Courtroom 10D why Counsel should not be sanctioned under Rule 11 and the court's inherent power for alleged citations to non-existent cases and misrepresentations of existing case law in Defendant's Motion to Strike Plaintiff's False Light Defamation Claim, (Dkt. 26 ("Motion")). It also appears that Counsel may have misused artificial intelligence here. If Counsel wish to file a written response beyond the reply in support of the Motion, (Dkt. 37), Counsel may do so on or before October 17, 2025. (es) (Entered: 10/14/2025)

SLAUGHTER, UNITED STATES DISTRICT JUDGE Rolls Royce Paschal N/A Deputy Clerk Court Reporter Attorneys Present for Plaintiff: Attorneys Present for Defendants: Not Present Not Present PROCEEDINGS: (IN CHAMBERS) ORDER TO SHOW CAUSE REGARDING SANCTIONS The court ORDERS Defendant Christian Epting’s Counsel to show cause at an in-person hearing on Thursday, October 23, 2025, at 10:00 a.m. in Courtroom 10D why Counsel should not be sanctioned under Rule 11 and the court’s inherent power for alleged citations to non-existent cases and misrepresentations of existing case law in Defendant’s Motion to Strike Plaintiff’s False Light Defamation Claim, (Dkt.

What the text mentions

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More from District Court, C.D. California, from California, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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