Segui v. Moniz
U.S. District Court, District of Arizona · D. Ariz. · Arizona bar guidance
Verified October 1, 2026
- Citation
- Segui v. Moniz, No. CV-25-01849-PHX-SHD (D. Ariz. Mar. 24, 2026)
- Filing date
- March 24, 2026
Summary
Plaintiffs' counsel cited Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011 (Ct. App. 2005) for the proposition that Arizona's civil RICO statute carries a four-year limitations period. Judge Sharad H. Desai found that the case does not exist and that the proposition for which it was cited was also incorrect, the correct period under A.R.S. section 13-2314.04(F) being three years. The Court raised the issue sua sponte after granting in part defendant Stephanie Stromfors's motion to dismiss.
- AI tool:
- Unspecified generative AI
What is the current procedural posture?
Order to show cause issued sua sponte under Fed. R. Civ. P. 11(c)(3) directing Plaintiffs' counsel to show cause in writing within twenty days why sanctions should not be imposed under Rule 11(b)(2) for citation to a nonexistent case. No monetary sanction imposed in this order. Stromfors's separate request for Rule 11 and 28 U.S.C. section 1927 sanctions was denied without prejudice on procedural grounds. Counsel responded on April 10, 2026 (Doc. 30); no ruling appears in the docket text on CourtListener through June 10, 2026.
Why does Segui v. Moniz matter for law firms using AI?
Segui v. Moniz illustrates how AI-fabricated citations can surface in run-of-the-mill state-law arguments embedded in federal motion practice. The fabricated authority appeared in a routine statute-of-limitations brief, was caught by the court rather than opposing counsel, and triggered a Rule 11 show-cause order on the court’s own initiative. The order is also notable for the judge’s express recognition that fabricated citations may originate from generative AI, signaling that District of Arizona judges are now scanning for the pattern.
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.