Stephen Lohbeck v. Amazon.com Services, LLC
Decided 2026-08-20 · Outcome: Warning · AI tool: Implied.
17 sanctioned cases on record in E.D. California where an attorney filed briefs, motions, or other pleadings containing AI-fabricated citations. Every entry below traces to a real, publicly reported court ruling. Data pulled daily from the underlying dockets and reporter databases — last update within 24 hours.
How courts in E.D. California have responded when a filing contained fabricated citations.
Filings in this jurisdiction most often cite the tool as “Implied” (the ruling describes an AI-generated brief but does not name a product).
Across 17 documented sanctions in E.D. California, the most common judicial response is Warning (5 of 17). Of the 17 cases, 2 carried an explicit monetary penalty in the ruling text.
The rulings in this jurisdiction are consistent with the pattern Citation Safe tracks nationally: when a court identifies a fabricated citation, the sanction almost always follows within days, not weeks. The attorney of record — not the AI — is on the hook. Rule 11 (federal), state analogs, and inherent authority all support monetary sanctions, disgorgement, adverse-costs orders, and bar referrals independent of the tool that produced the citation.
Practical implication: any brief that reaches a docket in E.D. California needs a citation-existence check before filing. Existence is Layer 1 — the case has to be real. Layer 2 is quote accuracy (any quoted language must actually appear in the opinion). Layer 3 is propositional support (the opinion must actually stand for what you cite it for). Every documented sanction below failed at Layer 1 or Layer 2 — the kind of failure that is trivially catchable before filing and catastrophically visible after.
Sample penalty language from this jurisdiction: “1000 USD”; “1500 USD”.
Decided 2026-08-20 · Outcome: Warning · AI tool: Implied.
Decided 2026-07-24 · Outcome: Admonishment & Warning · AI tool: Implied.
Decided 2026-07-16 · Outcome: Warning · AI tool: Implied.
Decided 2026-05-21 · Outcome: No Sanctions in circumstances · AI tool: ChatGPT.
Decided 2026-05-12 · Outcome: Warning · AI tool: Implied.
Decided 2026-04-22 · Outcome: Monetary Sanction; Bar Referral · Penalty: 1000 USD · AI tool: Implied.
Decided 2026-04-14 · Outcome: Order to Show Cause · AI tool: Implied.
Decided 2026-04-06 · Outcome: Order to Show Cause · AI tool: Implied.
Decided 2026-02-24 · Outcome: Order to Show Cause · AI tool: Implied.
Decided 2026-02-09 · Outcome: Order to Show Cause · AI tool: Implied.
Decided 2026-01-22 · Outcome: Order to inform client and staff of errors · AI tool: ChatGPT.
Decided 2026-01-14 · AI tool: Implied.
Decided 2025-12-03 · Outcome: Warning · AI tool: Implied.
Decided 2025-09-19 · Outcome: Order to show cause discharged; Admonishment · AI tool: Unidentified.
Decided 2025-09-09 · Outcome: Monetary sanction; Order to be server on client; State Bar notified · Penalty: 1500 USD · AI tool: Implied.
Decided 2025-08-04 · Outcome: Warning · AI tool: Implied.
Decided 2025-07-11 · Outcome: Order to show cause issued for potential sanctions · AI tool: Unidentified.
Other courts on the Citation Safe sanctions database with a similar volume of AI-hallucination rulings on record.
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Informational only. Not legal advice. Data derived from public court records; corrections at /contact.