Krista C. Geddes v. LoanCare, LLC, et al.
U.S. District Court, Eastern District of California · E.D. Cal. · California bar guidance
Conduct
An attorney misquoted a real case with words it does not contain, a classic AI-fabrication signature.
Consequence
$1,000 monetary sanction plus referral to the State Bar of California.
Lesson
The bar referral, not the dollar amount, is what moves malpractice premiums.
Verified May 14, 2026
- Citation
- Geddes v. LoanCare, LLC, No. 2:25-cv-02955-DMC (E.D. Cal. Apr. 22, 2026) (Cota, Mag. J.)
- Decided
- April 22, 2026
Summary
Plaintiff Krista C. Geddes, a California attorney appearing in the matter, submitted briefing that misquoted and overstated the scope of Kachlon v. Markowitz. The court found the quoted language did not appear in the cited opinion, a hallmark of unverified AI-generated drafting. The order treated the misattribution as a sanctionable failure to verify cited authority before filing.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 monetary sanction imposed and a referral to the State Bar of California for further review.
Why does Krista C. Geddes v. LoanCare, LLC, et al. matter for law firms using AI?
Geddes is a useful data point for managing partners because the misconduct is small in dollar terms but carries a bar referral, the consequence that actually moves malpractice premiums and partnership capital. The hallucination pattern, a real case cited with words it does not contain, is the variant most likely to slip past a quick proofread, and the one a documented verification step in a firm’s AI policy is designed to catch.
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.