Angelica E. Cruz et al. v. United States of America
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 5, 2026
- Citation
- Cruz v. United States, No. 2:24-cv-01087-MRA-PVC (C.D. Cal. Dec. 16, 2025) (order to show cause)
- Decided
- December 16, 2025
Summary
Plaintiffs' counsel filed an opposition brief citing Kennedy v. United States, 2022 WL 17684317 (C.D. Cal. Oct. 3, 2022), which neither opposing counsel nor the Court could locate. At a December 15, 2025 hearing, Plaintiffs' counsel blamed an unnamed outside counsel who had purportedly drafted the opposition and was unreachable while traveling in Costa Rica, and conceded that he had signed the brief without independently checking the citations. Judge Monica Ramirez Almadani found these responses "clearly unsatisfactory and unacceptable." The opposition was also filed roughly a week late under Local Rule 7-9 with no leave sought.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to Show Cause issued December 16, 2025, requiring Plaintiffs' counsel to show cause in writing within three days why sanctions should not be imposed under Rule 11(b) for citing a hallucinated case and for failing to file a timely opposition under Local Rule 7-9.
Why does Angelica E. Cruz et al. v. United States of America matter for law firms using AI?
Cruz illustrates how the “outside counsel drafted it” defense fails when the signing attorney has not independently verified citations. For a managing partner, the case underscores that Rule 11(b) liability runs with the signature, and that delegating drafting to contract or co-counsel does not delegate the duty to confirm that cited authority exists.
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.