Mareiorozyan v. Automobili Lamborghini America, LLC

What did the court warn about?

In a November 19, 2025 minute order adopting its tentative ruling, Judge Valerie Salkin granted Midway's motion for summary judgment. On the citation, the court "considered imposing sanctions on Plaintiff's counsel and ordering reporting to the State Bar," but, "in light of the Court's ruling against Plaintiff on the summary judgment motion," elected "not to impose monetary sanctions against Plaintiff's counsel at this time and not to report Counsel's misconduct to the State Bar." It "strongly admonishes Plaintiff's counsel for including a citation to a nonexistent case to support a legal position in Plaintiff's opposition brief," and warned: "If the nonexistent citation was the result of counsel using AI, counsel is warned that such conduct clearly falls below acceptable standards of conduct for attorneys working in our court system. Repeated instances of this misconduct will result in sanctions." The court denied the motion to disqualify counsel without prejudice as moot, stating it would revisit the issue if there were further litigation.

Why does Mareiorozyan v. Automobili Lamborghini America, LLC matter for law firms using AI?

Mareiorozyan is a Los Angeles lemon-law case in which the citation problem was resolved alongside summary judgment. The lessor, Midway, showed that the plaintiff had initialed his lease to indicate the car would be used primarily for business, which put the claim outside the Song-Beverly Act, and the court granted judgment on that ground. The plaintiff’s opposition had relied in part on “FCA US LLC v. Superior Court, 51 Cal.App.5th 1069 (2020),” and the court found that “[n]o such case exists.”

The court’s treatment of AI is careful. Midway’s counsel filed a declaration with the searches it ran and argued that the citation came from counsel’s improper use of AI to draft the brief. The court called that a persuasive and “compelling argument,” quoted a passage in Noland v. Land of the Free (itself quoting a federal district court) that there is “no room in our court system” for fake, hallucinated citations, and then warned counsel in conditional terms: “If the nonexistent citation was the result of counsel using AI,” the conduct “clearly falls below acceptable standards.” It did not find that AI was used.

The consequence was an admonishment rather than a sanction. The court said it had considered monetary sanctions and a State Bar report, and it declined both “in light of the Court’s ruling against Plaintiff on the summary judgment motion,” while warning that repeat conduct will be sanctioned. Firms documenting compliance may wish to consider that, here, the court’s restraint was expressly tied to the merits outcome, that it declined monetary sanctions “at this time,” and that opposing counsel’s documented search effort formed part of the record the court relied on.