Estate of Khallid Muhammad et al. v. Tupac Shakur Estate et al.
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 14, 2026
- Citation
- Estate of Khallid Muhammad v. Tupac Shakur Estate, No. 2:25-cv-02540-JLS-JPR (C.D. Cal. Feb. 26, 2026) (Staton, J.) (Order to Show Cause)
- Decided
- February 26, 2026
Summary
Copyright infringement action by the estate of Dr. Khallid Abdul Muhammad against the Tupac Shakur estate, Suge Knight, Interscope Records, Death Row Records, Universal Music Publishing, and producer Darryl "Big D" Harper, alleging unauthorized use of a 1993 Muhammad speech sampled in the 1996 Makaveli track "White Man'z World." Plaintiff is represented by attorney Malik Zulu Shabazz. After identifying citations to non-existent authority in plaintiffs' opposition to a motion to intervene, District Judge Josephine L. Staton ordered plaintiffs to explain the citations and to disclose any use of artificial intelligence. Plaintiffs responded but did not disclose any AI use, conceding that one cited federal case "does not seem to exist" and another "does not correspond to any publicly-retrievable decision." Finding that response "both vague and deficient," the court issued an Order to Show Cause on February 26, 2026.
- AI tool:
- Suspected generative AI; the court ordered plaintiffs to disclose any AI use, and plaintiffs did not disclose any in response
What sanction did the court impose?
The court ordered plaintiffs to appear on March 6, 2026 to show cause why they should not be sanctioned for providing non-existent case citations. No monetary sanction or disciplinary referral is imposed in the show-cause order itself.
Why does Estate of Khallid Muhammad et al. v. Tupac Shakur Estate et al. matter for law firms using AI?
This Central District of California copyright matter surfaced in Eugene Volokh’s running catalog of suspected AI-hallucinated court filings, suggesting the court’s February 26, 2026 Order to Show Cause concerns citations in plaintiff’s briefing rather than the merits of the sampling claim. For managing partners, the lesson sits in the staffing pattern, not the music industry facts: a solo or small-team plaintiff’s-side practice handling a high-profile federal copyright case is exactly the workflow where unverified AI-assisted research tends to slip through, and an OSC is the cheapest possible warning shot before Rule 11 sanctions or a State Bar referral. Firms documenting compliance should treat any OSC referencing citation accuracy as a trigger for an immediate file-level audit of every authority in the underlying brief.
Sources
Primary sources
Further reading
- https://www.blackenterprise.com/tupac-shakur-sued-by-dr-khallid-muhammad/
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
- Justia (legal aggregator)
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.
- Whether the March 6, 2026 show-cause hearing resulted in monetary sanctions, dismissal, withdrawal of filings, or referral to the State Bar of California is not visible from this order.