N.Z. v. Fenix International Limited
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified April 26, 2026
- Citation
- N.Z. v. Fenix Int'l Ltd., No. 8:24-cv-01655-FWS-SSC (C.D. Cal. Dec. 12, 2025)
- Decided
- December 12, 2025
Summary
Co-counsel Celeste Boyd used ChatGPT to draft large portions of four opposition briefs filed on behalf of plaintiffs against OnlyFans parent Fenix International, and failed to verify the AI-generated material. The briefs contained hallucinated authority, misquoted parentheticals, mischaracterized cases (including citing In re Hulu Privacy Litigation as imposing liability when the court had granted Hulu summary judgment), and incorrect record citations. Lead counsel Robert Carey of Hagens Berman Sobol Shapiro LLP filed the briefs without a full cite-check, relying on Boyd's prior reputation. Judge Fred W. Slaughter denied the motion to withdraw and substitute corrective briefs after finding the proposed corrections themselves still contained errors.
- AI tool:
- ChatGPT
- Sanction amount:
- $13,000
What sanction did the court impose?
Carey and Hagens Berman ordered to pay $10,000 jointly and severally; Boyd ordered to pay $3,000; both payable to the court within seven days. Hagens Berman must file a corrective-measures status report within 14 days and include a citation-accuracy certification with all subsequent briefing in the case. Clerk directed to serve the order on the California State Bar (Boyd) and the Arizona State Bar (Carey).
Why does N.Z. v. Fenix International Limited matter for law firms using AI?
The Fenix order is notable for two reasons managing partners should track. First, the court sanctioned both the AI-using co-counsel and the supervising lead counsel and law firm under Rule 11, citing California Rule of Professional Conduct 5.1(b)‘s supervisory duty: not knowing a colleague used AI does not insulate the signing attorney or the firm. Second, the court refused to allow corrective briefing at all, finding it would compound rather than remediate harm to defendants who had already spent resources surfacing the hallucinations. The bar referrals to two state bars and the standing certification requirement on all future filings in the case raise the practical cost well above the $13,000 monetary component.
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.