Churchill Funding I LLC v. 732 Indiana, LLC
Superior Court of California, County of Los Angeles, West District (Santa Monica) · Cal. Super. Ct. (L.A. Cnty.) · California bar guidance
Verified September 29, 2026
- Citation
- Churchill Funding I LLC v. 732 Indiana, LLC, No. 24SMCV03940 (Cal. Super. Ct. L.A. Cnty. Oct. 31, 2024) (Mandel, J.)
- Decided
- October 31, 2024
Summary
In a judicial foreclosure action over defaulted loans "totaling over $10 million," defendants submitted a case management conference statement on 10/24/2024 "including authorities supposedely supporting their argument that plaintiff could not elect to pursue judicial and then non-judicial foreclosure simultaneously." Judge Elaine W. Mandel's minute order states that "The authority 'California Federal Bank v. Kwong (1991) 231 Cal.App.3d 1467, 1472' does not exist," and that the authority cited as "Security Pacific National Bank v. Wozab 231 Cal.App.3d at 1472-1473" was "reported at 51 Cal.3d 991." The order does not mention artificial intelligence.
- AI tool:
- Not mentioned in the order
How did the court address the AI-related conduct?
The court stated: "The court will set an OSC re filing false pleadings with the court." In the same order it granted plaintiff's ex parte application for appointment of a receiver and a preliminary injunction requiring defendants to cooperate with the receiver, and sustained plaintiff's objection to the Kenig declaration as not made under penalty of perjury. No sanction was imposed in this order, and the court's register of actions shows no OSC re false pleadings being set before the action was dismissed under Code of Civil Procedure section 664.6 in November 2025.
Why does Churchill Funding I LLC v. 732 Indiana, LLC matter for law firms using AI?
Churchill Funding shows a nonexistent citation surfacing in routine state-court practice: a case management conference statement prepared for an informal meet and confer. The court’s minute order states that one cited authority “does not exist” and that another was misreported, and says the court will set an order to show cause regarding false pleadings. The register of actions shows a supplemental declaration by attorney Eliezer Appel “regarding authorities submited as part of the informal meet and confer” filed the day before the order, a peremptory challenge to Judge Mandel filed November 18, 2024, and the case’s reassignment to another department on February 10, 2025; it shows no OSC regarding false pleadings being set. The order is therefore a record of the problem and an announced consequence rather than a sanction. The order does not say whether AI was involved.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- AI attribution: the October 31, 2024 minute order does not mention AI or say how the nonexistent citation was produced. The entry is included because a third-party AI hallucination tracker lists it.
- The cited copy is a third-party tracker's mirror of the minute order. No court-hosted copy is reachable: the Los Angeles Superior Court's document images sit behind the PAOS login and fee system, and its free case-access register lists docket entries only.