Colbert v. County of Riverside
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 5, 2026
- Citation
- Colbert v. County of Riverside, No. 5:25-cv-01655-SP, 2026 WL 931542 (C.D. Cal. Mar. 31, 2026)
- Decided
- March 31, 2026
Summary
Plaintiff's counsel Royal D. L. Bond of Bond Law Legal Group submitted an opposition brief containing a fabricated quotation purporting to be from California Government Code section 845.4. Magistrate Judge Sheri Pym was unable to locate the quoted statutory language in section 845.4 or any other Government Code section, nor in any reported case. The court observed that this suggested counsel used artificial intelligence to draft the brief and failed to verify the citations and quotes.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction was imposed. The court issued a written admonishment in footnote 2 of its order, reminding counsel of obligations under California Rule of Professional Conduct 3.3(a)(1) and Federal Rule of Civil Procedure 11(b)(2), and noting that the absence of a local AI rule does not permit counsel to submit a brief with non-existent authority. The court cited Mata v. Avianca and Park v. Kim for counsel's duty to confirm the existence and validity of cited authorities.
Why does Colbert v. County of Riverside matter for law firms using AI?
Colbert illustrates how an AI-fabricated statutory quotation, rather than a fake case citation, can trigger judicial scrutiny. The hallucinated language appeared inside quotation marks attributed to a real code section, the kind of error that survives a cursory cite-check but collapses the moment a judge opens the statute. The court declined to impose monetary sanctions but memorialized the failure in a published order, leaving a discoverable record that opposing counsel and malpractice carriers can find by name.
Sources
Primary 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.