People v. Alvarez
California Court of Appeal, Fourth Appellate District, Division One · Cal. Ct. App. · California bar guidance
Verified April 26, 2026
- Citation
- People v. Alvarez, 114 Cal.App.5th 1115, No. D084581 (Cal. Ct. App. 4th Dist. Div. 1 Oct. 2, 2025)
- Decided
- October 2, 2025
Summary
Attorney LeRoy Siddell, appointed counsel for criminal defendant Raziel Ruiz Alvarez, filed an opposition to the People's motion to dismiss the appeal that included a fabricated quotation attributed to In re Benoit (1973) 10 Cal.3d 72, a citation to a non-existent case (People v. Robinson (2009) 172 Cal.App.4th 452), and two citations to cases that did not address the issues for which they were cited. After the court issued an order to show cause, Siddell admitted he had failed to verify cases provided by artificial intelligence and voluntarily withdrew from the representation.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,500
What sanction did the court impose?
$1,500 monetary sanction imposed on attorney Siddell, payable to the Fourth District Court of Appeal, Division One, with the State Bar of California notified. The opinion was certified for publication, making this one of the early published California appellate decisions sanctioning AI-related citation fabrication.
Why does People v. Alvarez matter for law firms using AI?
The sanctioned filing in Alvarez was a routine criminal-appellate opposition by court-appointed counsel, not a high-stakes civil brief. The fabricated authorities included a quotation falsely attributed to In re Benoit (1973) 10 Cal.3d 72, a non-existent People v. Robinson cite, and two real cases miscited for propositions they did not support. The panel certified the opinion for publication, imposed a $1,500 monetary sanction payable to the Fourth District, and notified the State Bar despite counsel’s voluntary withdrawal. The signal for criminal-defense and contract-counsel practices is that citation verification is a supervisory baseline, not a discretionary quality check.
Sources
Primary sources
Further reading
- https://caselaw.findlaw.com/court/crt-app-fou-dis-cal-div-one/117797485.html
- Justia (legal aggregator)
- Specific generative AI product used by counsel was not identified in the published opinion.