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Hunter Tellez v. Proiettii

U.S. District Court, Eastern District of California · E.D. Cal. · California bar guidance

Pro-se party

Conduct

Pro se litigant filed papers with both fabricated case law and real cases misrepresented for propositions they do not support.

Consequence

Warning issued by E.D. Cal. court; no monetary sanction.

Lesson

Mixed-mode AI hallucinations (fabricated cases plus misrepresented real cases) are now a single-warning event in E.D. Cal.

Court sanction

Verified May 7, 2026

Citation
Tellez v. Proiettii, No. 1:24-cv-00408 (E.D. Cal. Aug. 4, 2025) (Sherriff, J.)
Decided
August 4, 2025

Summary

Pro se litigant Hunter Tellez filed papers in an Eastern District of California matter that the court found contained fabricated case law and misrepresented case law (citations to real cases that do not stand for the propositions for which they were cited). The court issued a warning. The case is before Judge Kirk E. Sherriff.

AI tool:
Implied (court found fabricated and misrepresented case law; specific tool not identified)
This case summary is informational only. Verify the underlying opinion or order against the primary source before relying on it in any filing or client matter.

What sanction did the court impose?

Warning issued; no monetary sanction or formal disciplinary referral on the available record.

Why does Hunter Tellez v. Proiettii matter for law firms using AI?

Tellez v. Proiettii is an Eastern District of California pro se warning case notable for the dual hallucination pattern: both fully fabricated case law and real case law misrepresented for propositions the cited opinions do not support. The court treated both categories as a single warning event, consistent with the broader federal pattern of first-occurrence pro se warnings rather than monetary sanctions.

For firms with E.D. Cal. matters opposed by pro se filers, the case illustrates that cite-checking must extend beyond verifying case existence to verifying that real cases stand for the propositions they are cited for. Misrepresented real cases are a distinct AI-hallucination subtype identified across multiple 2025 federal sanctions orders, and Tellez establishes that E.D. Cal. treats them as sanctionable on the same footing as fabricated citations.

Implications for your firm

Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.

  • When opposing pro se litigants in E.D. Cal., expect both pure fabrications and misrepresented real cases in the same brief; the cite-checking workflow needs to verify both case existence and propositional support, not just the former.
  • The Tellez warning is consistent with the broader federal pattern of first-occurrence pro se warnings rather than monetary sanctions, suggesting cross-circuit convergence on the warning-first disposition.

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Sanctions cases

From the blog

Sources

Primary sources

Unverified claims:
  • Charlotin's database lists this case but does not link a primary-source PDF; the only confirmed primary-tier reference is the CourtListener docket. The substantive description of the fabricated and misrepresented citations is per Charlotin's CSV synopsis without an underlying PDF.
  • The defendant's name is spelled 'Proiettii' (double-i) on the CourtListener docket and in Charlotin's database; R&G's tracker uses 'Proietti' (single-i). The CourtListener spelling is canonical.
  • Judge identification (Kirk E. Sherriff) is per R&G's tracker; not independently verified against the order text.