Puig Valdes v. All3Media America, LLC
Los Angeles County Superior Court · L.A. Super. Ct. · California bar guidance
Verified April 26, 2026
- Citation
- Puig Valdes v. All3Media America, LLC, No. 25STCV15503 (L.A. Super. Ct. Oct. 2025)
- Decided
- October 15, 2025
Summary
Plaintiff's counsel Paul J. Denis of Denis & Rasi PC in Irvine submitted an opposition to All3Media's anti-SLAPP motion containing fabricated case citations, including "Edwards v. Hearst Corp. (1991) 53 Cal.3d 30" and "Heath v. San Joaquin Comm. Hosp. Dist. (1993) 15 Cal.App.4th 708," neither of which exists in California reporters. Counsel acknowledged the citations were generated by ChatGPT and not independently verified. Judge Peter A. Hernandez denied a motion to correct the errors and addressed the conduct on the record.
- AI tool:
- ChatGPT
What sanction did the court impose?
No monetary sanction issued, but the court alerted the parties that the conduct would be referred to the Chief Trial Counsel of the State Bar of California for further investigation. The court separately granted the defendants' anti-SLAPP motion, dismissing Puig's defamation claim on the ground that the challenged statements were substantially true and protected by California's fair report privilege.
Why does Puig Valdes v. All3Media America, LLC matter for law firms using AI?
Puig v. All3Media is a high-visibility California state-court example of the same failure pattern as Mata v. Avianca, but with a state bar referral rather than a court-imposed monetary sanction. For California firms, the case underscores that an anti-SLAPP opposition, like any other filing, is a representation to the court under Rule 3.3 of the California Rules of Professional Conduct, and that running citations through ChatGPT without verification is now a documented path to a Chief Trial Counsel referral.
Sources
Further reading
- https://reason.com/wp-content/uploads/2025/10/PuigValdesvAll3MediaReducedSize.pdf
- https://www.dailyjournal.com/articles/387962-judge-blasts-yasiel-puig-s-lawyer-for-ai-faults-but-considers-his-argument
- https://reason.com/volokh/2025/10/27/yasiel-puig-ai-hallucinated-citations-gambling-and-libel/
- Exact signing date of the written ruling. The hearing was Oct. 9, 2025; the order was reported by Volokh on Oct. 27, 2025. The 2025-10-15 date is approximate pending direct OCR of the order PDF.