Sanchez v. Chedraui USA, Inc.

How did the court address the AI-related conduct?

In the November 6, 2025 minute order, Judge Lisa R. Jaskol granted the store's motion for summary judgment. The court concluded that a moving defendant need not present evidence about its inspections when it shows that the substance was on the floor too briefly to support an inference that it failed to exercise due care, that the store had carried its initial burden of showing it lacked actual and constructive notice, and that plaintiff presented no evidence raising a triable issue of fact. On December 11, 2025, the order to show cause was not called for hearing. The court stated that it was "in receipt of the Declaration of Plaintiff's Counsel Jennine Nwoko, Esq. Regarding Citation Clarification filed by Plaintiff on 11/06/2025," and, "[a]fter review of the case file in chambers," ruled: "The Court has reviewed counsel's response to the order to show cause. The Court discharges the order to show cause." The December 11 minute order does not describe the declaration's contents, makes no finding on whether the citation was fabricated, and imposes no sanction. It also states that the final status conference and trial remain as previously set, pending action as to Does 1 to 25.

Why does Sanchez v. Chedraui USA, Inc. matter for law firms using AI?

Sanchez is a Los Angeles slip-and-fall case in which a single unlocatable citation led to an order to show cause. The store’s evidence, which plaintiff did not dispute, was that the salsa had been on the floor for about four minutes before the fall. Plaintiff argued that even brief windows of time may support constructive notice in high-traffic areas and cited “Briganti v. Chow King, Inc. (2022) 81 Cal.App.5th 776” for the point. The court wrote that it “could not locate” that case; relying on the reasoning of Ortega v. Kmart Corp., Gonzalez v. Interstate Cleaning Corporation and Girvitz v. Boys’ Market, it held that the store had no constructive notice and granted summary judgment, and it issued an order to show cause why plaintiff’s counsel should not be sanctioned for “providing a fabricated case citation.”

The court made no finding that the case does not exist: it said it could not locate it, and although the order to show cause is framed as one for “providing a fabricated case citation,” it ordered counsel to file a declaration “explaining whether” the citation is fabricated. The orders do not mention artificial intelligence.

The order to show cause ended without a sanction. On December 11, 2025, without calling the matter for hearing, the court noted receipt of counsel’s declaration “Regarding Citation Clarification,” reviewed the file in chambers, and discharged the order to show cause. The minute order does not say what the declaration explained. Firms documenting compliance may wish to consider that, here, the court paired the order to show cause with a required written explanation of whether the citation was fabricated, and that the discharge left no finding on what the citation was or where it came from.