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 75, 13 October 2026 · source · PDF · 3 pages
Docket text. ORDER IMPOSING SANCTIONS. The Court ORDERS King to include in all future correspondence with opposing counsel (including discovery responses) and in all future filings with the Court a statement, made under penalty of perjury, addressing whether generative AI was used, as detailed herein. The Court LIFTS the stay in this case. Signed by Judge Lauren King. (KRA)
CASE NO. 2:25-cv-02270-LK ORDER IMPOSING SANCTIONS This matter comes before the Court on Plaintiff Jtwain King’s response to the Court’s Order to Show Cause why the Court should not impose sanctions for her failure to abide by applicable rules and her reliance on artificial intelligence to litigate her case for her (including her submission of citations to nonexistent cases in her opposition brief to Defendant Equifax’s motion for judgment on the pleadings) . Dkt.
2. “Ordering King to pay the attorney’s fees Equifax incurred in responding to her ORDER IMPOSING SANCTIONS - hallucinated citations.” Id. at 13. 3.
She avers that “[t]o the best of [her] knowledge, [e]very fact and citation in [her] filings were verified through [her] own work aside from minor errors.” Id. at 1. As for the seemingly hallucinated cases, King “acknowledges possible citation verification errors,” but claims that she “did not knowingly fabricate authority” and corrected the errors “through a formal filing” after she discovered them. Id. at 2.
However, the Court does not find her assertions that the hallucinated cases were merely “citation verification errors” to be credible.
No. 74 at 8, the Court elects not to require her to pay the attorney’s fees Equifax incurred in responding to her hallucinated citations. However, the Court warns that it may impose sanctions, up to and including dismissal, for any future violations of applicable rules or Court orders .
Docket entry 73, 9 September 2026 · source · PDF · 14 pages
Docket text. ORDER GRANTING MOTION FOR JUDGMENT ON THE PLEADINGS AND ORDER TO SHOW CAUSE. King is ORDERED to show cause by no later than 9/29/2026, why the Court should not impose the herein detailed sanctions. Equifax's and Experian's Motion for Judgme nt on the Pleadings is GRANTED. Dkt. Nos. 43 , 45 . King's claims against Equifax and Experian are DISMISSED. The Court STAYS this case until it decides whether to dismiss the remainder of King's claims pursuant to its Order to Show Cause. Signed by Judge Lauren King. (KRA)
Ritchie, 342 F.3d 903, 908 (9th Cir. 4 King frivolously a sserts that Equifax’s arguments regarding her use of hallucinated case citations w ere improper. Dkt.
72. And her opposition brief to Equifax’s motion contains citations to nonexistent cases. After Equifax pointed out the hallucinated cases, Dkt.
LCR 10(e)(6) (“[C]itations to legal authority must include page numbers.”). Furthermore, neither of the “corrected citations” stand for the propositions that King represented the non-existent cases to stand for in her opposition. Dkt.
No. 54-1 at 3–4, these errors are hallmarks of nonexistent cases created through artificial intelligence. Specifically, “[a]s the instant case demonstrates, AI will insert case names and citations for cases that do not exist, or with a wrong court designation, or most critically, AI will invent or fabricate language as quoted content that is not present in the cited case or tha t has nothing to do with the subject matter of it.” United States v.
11(c)(1). 9 King also provides a nonexistent cite for Gross v. CitiMortgage .
20-35270, 2022 WR 1552285,” which does not exist, even when replacing “WR” with “WL”). ORDER GRANTING MOTION FOR JUDGMENT ON THE PLEADINGS AND ORDER TO SHOW CAUSE - Inclusion of nonexistent authority in a brief “is plainly a violation of a signer’s certification under Rule 11 that ‘to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claim s, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law.’” Lewis v. Eagle Cnty.
2023). Indeed, citation to nonexistent legal authority “is fundamentally frivolous[.]” Lewis, 2025 WL 3639608, at *6. Pro se plaintiffs do not have greater rights than plaintiffs represented by counsel, Jacobsen v.
If the Court does not dismiss her case, it is considering imposing the following alternative sanctions: 1. Ordering King to pay the attorney’s fees Equifax incurred in responding to her hallucinated citations. Dkt.