Flowz Digital LLC v. Dalal
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified April 26, 2026
- Citation
- Flowz Digital LLC v. Dalal, No. 2:25-cv-00709-SB-PVC (C.D. Cal. May 5, 2025)
- Decided
- May 5, 2025
Summary
Plaintiff's counsel Omid Khalifeh filed an opposition to a motion to dismiss containing citations the court could not reconcile with the cited authority, including a nonexistent decision the court could not locate, Shell Petroleum N.V. v. Republic of Costa Rica, 608 F. Supp. 2d 269 (S.D.N.Y. 2009). After Judge Stanley Blumenfeld, Jr. ordered disclosure, counsel admitted using an AI tool to identify potentially relevant authorities and organize arguments, without filing the AI-use declaration required by the court's Civil Standing Order. Two other cited cases, In re Daou Systems and S.E.C. v. Cross Financial Services, were misrepresented as standing for propositions the decisions did not support.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause issued May 5, 2025, requiring plaintiff and counsel to show cause by May 12, 2025 why they should not be sanctioned under Rule 16(f) for violating the Standing Order's AI-disclosure requirement and under Rule 11 for filing an opposition without reasonable inquiry into whether the legal contentions were supported. No monetary sanction imposed in this order.
Why does Flowz Digital LLC v. Dalal matter for law firms using AI?
Flowz Digital illustrates how a judge’s standing order on AI disclosure can convert a routine briefing into a sanctions inquiry. The court flagged not just a fabricated citation but two real decisions cited for propositions they did not support, a failure mode AI-assisted research produces with some regularity. For firms whose litigators practice in C.D. Cal. or other districts with AI standing orders, the case underscores that the disclosure obligation is independent of, and runs parallel to, Rule 11’s verification duty.
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.
- Charlotin lists the AI tool as Lexis+ AI; the court's order does not name a specific tool, describing only 'an AI tool' used in early drafting.