Lin v. Leal

What sanction did the court impose?

Judge Lauren A. R. Lofton granted Gutierrez's motion for summary judgment in its entirety on October 23, 2025, after striking plaintiffs' separate statement for failing to comply with Code of Civil Procedure section 437c. At the December 9, 2025 hearing on the order to show cause, according to the minute order, "Counsel for the plaintiff informs the Court of the remedial measures his office has implemented to ensure the validity of citations in future filings." The court then ruled: "For plaintiff's reliance on fake and/or improper case citations, the Court sanctions plaintiff's counsel" as follows. The order states that "Speros Maniates, SBN 107782, is sanctioned by the Court" and orders payment of sanctions "in the amount of $500.00 to the Superior Court of California, County of Los Angeles by 01/12/2026 pursuant to Code of Civil Procedure section 177.5 for violation of Code of Civil Procedure section 128.7(b)(2)." The amount is half the $1,000 the order to show cause proposed; the minute order does not state why. It adds that failure to pay by the due date will result in the matter being forwarded to the court's Collections Division for referral to a private collections vendor without further notice or order. Neither order mentions artificial intelligence or refers counsel to the State Bar.

Why does Lin v. Leal matter for law firms using AI?

Lin is a Los Angeles commercial lease and guaranty case in which the court found the citation problems itself while deciding summary judgment. The moving defendant, Encarnacion Gutierrez, argued that the 2017 guaranty covered only his and a co-signer’s own debts and that the 2019 lease documents contained no enforceable guaranty. Opposing that motion, plaintiffs cited “Mutual Benefit Life Ins. Co. v. Grigsby” for the proposition that a guaranty can survive cancellation of the lease; the court wrote that the case “does not exist,” and that neither its name nor its citation appears to exist. Plaintiffs also cited Sumitomo Bank v. Iwasaki with the wrong year and reporter, and the court found that the Sumitomo case did not appear to support the position for which plaintiffs offered it.

The court acted “on its own motion.” It set an order to show cause why plaintiffs’ counsel should not be sanctioned $1,000 for violating Code of Civil Procedure section 128.7(b)(2) “by citing fake and/or improper cases.” Neither the summary judgment order nor the sanctions order mentions artificial intelligence.

At the December 9, 2025 hearing, counsel told the court about remedial measures his office had implemented to ensure the validity of citations in future filings. The court then sanctioned counsel $500, payable to the court under Code of Civil Procedure section 177.5, “[f]or plaintiff’s reliance on fake and/or improper case citations.” The minute order does not say whether the reported remedial measures affected the amount. Firms documenting compliance may wish to consider that, here, the court raised the issue itself, relied on section 128.7(b)(2) as the violated duty and section 177.5 as the vehicle for a payment to the court, and recorded counsel’s account of remedial steps in its order.