Modern Floor Specialists, Inc. v. City of Los Angeles
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 5, 2026
- Citation
- Modern Floor Specialists, Inc. v. City of Los Angeles, No. 2:25-cv-04765-ODW (JPRx) (C.D. Cal. Apr. 3, 2026)
- Decided
- April 3, 2026
Summary
Plaintiffs' counsel Joshua Matic cited a nonexistent Ninth Circuit decision, Mabee v. County of Orange, 784 F. App'x 585 (9th Cir. 2019), in opposition to a motion to dismiss. Judge Otis D. Wright II found that the cited reporter and pincite actually point to Cochran v. City of Wichita, an unrelated Tenth Circuit case, and that no case captioned Mabee v. County of Orange exists in any federal or state jurisdiction. The court ordered Matic to show cause why he should not be sanctioned for using artificial intelligence to perform legal research without verifying the citations.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Court issued an order to show cause requiring Matic to file a sworn declaration within three days addressing where he found Mabee, attaching a copy of the opinion, and explaining why he should not be sanctioned for using AI without a reasonable inquiry. The court also deferred ruling on a separate Rule 11 sanctions motion brought by the City Defendants and set both matters for hearing on April 14, 2026.
Why does Modern Floor Specialists, Inc. v. City of Los Angeles matter for law firms using AI?
The order is notable for pairing a routine motion-to-dismiss ruling with a freestanding AI-research OSC: Judge Wright treated the fabricated citation as an independent Rule 11 issue distinct from the merits dismissal and the parties’ competing sanctions motions. For managing partners, the case underscores that a single unverified AI-generated citation buried in an opposition brief can convert a losing motion into personal exposure for the signing attorney, separate from any client-driven litigation strategy.
Sources
Primary 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.