Heiting v. I Am Beyond LLC
Superior Court of California, County of Los Angeles · Cal. Super. Ct. (L.A. County) · California bar guidance
Verified April 26, 2026
- Citation
- Heiting v. I Am Beyond LLC, No. 23STCV27729 (Cal. Super. Ct. L.A. County Jan. 13, 2026)
- Decided
- January 13, 2026
Summary
Plaintiff's counsel Robert Tauler filed an opposition to summary judgment containing quotations attributed to In re Facebook, Inc. Internet Tracking Litigation, 956 F.3d 589 (9th Cir. 2020), and Cline v. Reetz-Laiolo, 329 F. Supp. 3d 1000 (N.D. Cal. 2018), that did not appear in either opinion. Judge Carolyn B. Kuhl found it likely the briefing was influenced by AI hallucinations that counsel did not verify before filing, and granted the defendant's motion for summary judgment on the merits.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanctions imposed. The court declined to sanction Mr. Tauler but warned that if its summary judgment ruling were reversed on appeal and Tauler sought class certification, the court would consider whether his lapses of duty rendered him inadequate as class counsel. The court cited Noland v. Land of the Free, L.P., 114 Cal.App.5th 426 (2025), as authority for sanctioning AI-generated fabricated citations.
Why does Heiting v. I Am Beyond LLC matter for law firms using AI?
Heiting illustrates a softer judicial response that still carries professional consequences. The court declined monetary sanctions but flagged on the record that counsel’s reliance on fabricated quotations could later disqualify him from serving as class counsel. For a managing partner, the lesson is that even when a court withholds Rule 11 style discipline, the adequacy-of-counsel finding it foreshadows can be more damaging to a contingent-fee class practice than a fee award.
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.