David v. George Chiala Farms, Inc.
U.S. District Court, Northern District of California · N.D. Cal. · California bar guidance
Verified April 26, 2026
- Citation
- David v. George Chiala Farms, Inc., No. 24-cv-04040-SI (N.D. Cal. Nov. 7, 2025)
- Decided
- November 7, 2025
Summary
Counsel for plaintiff Marc Henri David and for third-party defendants Catharine David and Catharine David Consulting filed motions to dismiss citing two nonexistent cases and misquoting a state statute. Plaintiff's motion cited Morgan v. State of California, 157 Cal. App. 4th 914 (2007) for a proposition about Cal. Civ. Code § 988; the reporter citation actually points to Perrillo v. Picco & Presley, an unrelated workers' compensation case. The same brief misquoted § 988(c) itself. The CDC motion later cited Humphries v. Rice, 88 Cal. App. 4th 1413 (2001) for a fiduciary-duty proposition; that reporter cite resolves to Galvez v. Frields, a medical malpractice case, and the case name "Humphries v. Rice" returns only an unrelated Alabama dog-attack tort. Judge Susan Illston admonished the Davids and their counsel on the record and declined to credit the second fabricated-citation argument on its merits.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. Judge Illston twice admonished counsel in the written order, refused to credit the argument supported by the second fabricated case, and warned that further violations of the local rules or further fabricated citations could result in sua sponte striking of filings. The court otherwise resolved the underlying motions to dismiss on the merits and granted leave to amend.
Why does David v. George Chiala Farms, Inc. matter for law firms using AI?
David v. Chiala Farms is notable because the same lawsuit produced two fabricated case citations from counsel on the same side, in two separate briefs, prompting the court to escalate from a single admonishment to a refusal to credit the second argument on its merits. For managing partners, it underscores that a “one-off” hallucination defense becomes much harder to sustain once a second fabricated citation appears in the same matter, and that judges are increasingly building a paper trail of warnings before reaching for monetary sanctions.
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.
- The order does not name a specific generative AI tool. Charlotin's queue flags this as an "Implied" AI case based on the pattern of multiple fabricated citations and misquoted statutory text, but the order itself does not attribute the errors to AI use.