Antonia Meza Roman v. County of Los Angeles

What did the court warn about?

In an August 27, 2025 minute order adopting its tentative ruling, Judge Michael B. Wilson denied the motion in full. The court found that the moving defendants had not carried their initial burden on either argument: the plaintiff's expert and deposition evidence indicated that the water was visually camouflaged and difficult to detect, that the location was a high-traffic area on the building's main evacuation route, and that she needed that route because the alternative was uncovered in the rain; the moving defendants' knowledge of recurring water pooling next to the location, together with two to three days of windy and rainy weather, was circumstantial evidence bearing on notice. In its conclusion the court turned to the citations: "Plaintiff's opposition cites legal authority that either does not exist or does not stand for the cited propositions. Counsel is admonished that any further citation to nonexistent legal authority or misrepresentation as to the import of cited authority will result in the Court setting an OSC re: sanctions and referral to the State Bar for disciplinary action for providing false citations of legal authority." The order imposes no sanction, sets no hearing on the citations, and makes no referral. No party appeared at the hearing.

Why does Antonia Meza Roman v. County of Los Angeles matter for law firms using AI?

Roman is a Los Angeles premises liability case in which the party whose brief contained the defective citations won the motion. The plaintiff slipped on water on an interior laminate floor next to an exterior concrete area where, according to her additional material facts, rainwater pooled and was carried inside by foot traffic and wind. The defendants the court called the Managerial Defendants moved for summary judgment on the grounds that the hazard was open and obvious, that she could have taken another route, and that they had no notice. Judge Wilson found they had not met their initial burden on any of those points and denied the motion.

The citation problems are recorded in three footnotes and the conclusion. In footnotes 10 and 11 the court agreed with the moving defendants that cases the plaintiff relied on, including Krongos, Osborn, Alcaraz and Sprecher, “do not stand for the proposition cited by Plaintiff,” while noting that the moving defendants had failed to distinguish the plaintiff’s expert testimony. In footnote 12 it agreed with the moving defendants that two other citations, Fairchild v. Park County and Corgain v. Kmart Corp., do not exist: “no case exists with either name, and neither cited case exists at either reporter location.” The order does not mention artificial intelligence, and the Charlotin tracker’s AI coding is an inference the court did not make.

The consequence was a conditional warning. The court admonished counsel that “any further citation to nonexistent legal authority or misrepresentation as to the import of cited authority” will result in an OSC re: sanctions and a referral to the State Bar, and imposed nothing on this occasion. Firms documenting compliance may wish to consider that the court’s warning expressly reached misdescribed real authority as well as nonexistent cases, and that it was issued in an order that otherwise went the filer’s way.