Support Community, Inc. v. MPH International LLC
U.S. District Court, Northern District of California · N.D. Cal. · California bar guidance
Verified April 26, 2026
- Citation
- Support Community, Inc. v. MPH International LLC, No. 23-cv-04911-JSW (N.D. Cal. Oct. 6, 2025)
- Decided
- October 6, 2025
Summary
Defense counsel Mr. Russo filed a motion for summary judgment containing hallucinated case citations generated by AI. Mr. Russo conceded that portions of the brief had been drafted with generative AI without verifying the authority cited. Judge Jeffrey S. White found a Rule 11(b)(2) violation under the objective reasonable-inquiry standard, citing Park v. Kim and a growing line of AI-hallucination sanctions cases.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Court ordered Defendant to re-file the summary judgment motion by October 27, 2025 with all hallucinated cases and citations excised, and barred replacing them with new authority or argument. Plaintiff awarded reasonable attorneys' fees and costs for work performed after the opposition was filed. Mr. Russo ordered to self-report by sending a copy of the order to the State Bar of California and to serve a copy on his client, with proofs of service due by October 27, 2025.
Why does Support Community, Inc. v. MPH International LLC matter for law firms using AI?
Support Community v. MPH International illustrates a measured but pointed sanction model that small and mid-size firms should expect to see more often: rather than dollar penalties on counsel, the court forced the offending party to re-file the underlying motion with hallucinated citations stripped out and forbade substitution of new authority, while shifting fees and triggering a mandatory State Bar self-report. For managing partners, the operative risk is not just a Rule 11 fine but the loss of the substantive motion itself and a bar referral that follows the attorney across matters.
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.