Gharavi v. Google LLC
U.S. District Court, Northern District of California · N.D. Cal. · California bar guidance
Verified April 26, 2026
- Citation
- Gharavi v. Google LLC, No. 25-mc-80164-WHO, 2026 WL 82256 (N.D. Cal. Jan. 12, 2026)
- Decided
- January 12, 2026
Summary
Perkins Coie attorney Torryn T. Rodgers filed a sworn declaration listing fifteen prior pro se cases involving petitioner Nima Gharavi, including a fabricated Wisconsin criminal matter, "County of Racine v. Nima Gharavi, No. 2018TR008316." Rodgers stated she relied on Bloomberg Law search results returned by her firm's legal research staff. Gharavi, who had never litigated in Wisconsin, moved for $5,625 in compensatory sanctions against Rodgers under the court's inherent authority. Judge William H. Orrick declined to sanction.
- AI tool:
- Bloomberg Law
What sanction did the court impose?
Motion for sanctions DENIED. Judge Orrick held that reliance on Bloomberg Law, described as "a well-trusted database and legal search tool," was neither reckless nor in bad faith under Fink v. Gomez, particularly where the erroneous citation was not material to the underlying motion and Rodgers promptly filed a corrected declaration. Gharavi's companion motion to compel and motion to strike were also denied; Google's motion to strike was granted.
Why does Gharavi v. Google LLC matter for law firms using AI?
Gharavi is the first sanctions decision in the tracker that names Bloomberg Law as the source of a fabricated citation, and one of the rare orders to deny sanctions outright. Judge Orrick’s reasoning, that reliance on an established legal research database is not per se reckless and that promptly correcting an immaterial error defeats a bad-faith finding, gives firms a useful counterpoint to the Mata line: the duty of verification is real, but courts distinguish between AI-generated fabrications central to a brief and database errors collateral to it. Managing partners should still treat any unverified citation as a malpractice exposure, regardless of which tool produced it.
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.