Strike 3 Holdings, LLC v. Doe
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 6, 2026
- Citation
- Strike 3 Holdings, LLC v. Doe, No. 2:24-cv-8183-TJH (SPx), 2025 WL 882212 (C.D. Cal. Jan. 22, 2025)
- Decided
- January 22, 2025
Summary
Defendant John Doe's counsel Fre'Drisha M. Dixon of Dixon Law Partners filed a motion to quash plaintiff Strike 3 Holdings' subpoena to ISP Spectrum that cited three non-existent cases as legal authority. Magistrate Judge Sheri Pym was unable to locate any of the three citations and observed that, while one nonexistent citation might be a mere mistake, three together suggested counsel "may have used artificial intelligence to draft the motion and failed to confirm the accuracy of the citations." The court denied the motion to quash on the merits and addressed the fabricated authority in a separate section of the order.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction imposed. The court denied the motion to quash and the request to seal, but allowed the defendant to proceed pseudonymously. Judge Pym formally cautioned defendant's counsel that any further filings with citations to non-existent cases may result in sanctions, citing Park v. Kim, Mata v. Avianca, and Gauthier v. Goodyear as examples of consequences for similar conduct.
Why does Strike 3 Holdings, LLC v. Doe matter for law firms using AI?
Strike 3 illustrates how a court can put fabricated AI citations on the public record without imposing monetary sanctions, using the order itself as the deterrent. For a managing partner, the lesson is that the reputational hit, an opinion on Westlaw naming the firm and the lawyer for filing three nonexistent cases, often arrives well before any fee award. The order also signals that “the court has no AI-specific rule” is not a defense; Rule 11 and the state rules of professional conduct already do the work.
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.