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California · state appellate court · 2025

People v. Alvarez

California Court of Appeal, 3 October 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · Cal. Ct. App.

  1. Court. California Court of AppealCOURT
  2. Level. state appellate courtLEVEL
  3. Date. 3 October 2025DATED
  4. Docket. No. D084581DOCKET
  5. Documents. one document, 4 passages quoted belowON FILE
  6. 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.

Published opinion, 3 October 2025 · source · PDF · 6 pages

Alvarez. The opposition included a quotation attributed to In re Benoit (1973) 10 Cal.3d 72, 87–88, but the purported quote did not exist in the case. Attorney Siddell later clarified that it was not a direct quotation because he modified it “to incorporate broader principles.” The opposition also included a citation to a case that does not exist: People v.

At the hearing, Attorney Siddell apologized for failing to verify the legal citations and sources included in his motion and explained that this failure resulted from feeling rushed. He reported he had taken courses regarding artificial intelligence (AI) and was aware that AI could hallucinate cases, but he did not verify the accuracy of any citations. He explained he relies on staff to help draft motions and briefs, but he recognized it is his responsibility to check the caselaw before submitting documents to the court.

That did not happen here. Attorney Siddell admitted to violating his professional duty by including a hallucinated citation and misrepresenting the law provided in other opinions. We infer he knowingly made a false statement based on this admission.

(Rules of Prof. Conduct, rule 1.0.1(f).) He also violated rule 8.1115(a) of the California Rules of Court, which prohibits citation to unpublished opinions, because he cited a non-existent case, and rule 8.276(a)(4), which prohibits attorneys from committing unreasonable violations of the Rules of Court, because he misrepresented the substance of cases in filings before this court. (See Cal.

What the text mentions

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Where this fits

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More from California Court of Appeal, 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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