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Segui v. Moniz

U.S. District Court, District of Arizona · D. Ariz. · Arizona bar guidance

Court sanction

Verified May 5, 2026

Citation
Segui v. Moniz, No. CV-25-01849-PHX-SHD (D. Ariz. Mar. 24, 2026)
Decided
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.

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What sanction did the court impose?

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.

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.