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Twist It Up, Inc. v. Annie International, Inc.

U.S. District Court, Central District of California · C.D. Cal. · California bar guidance

Court sanction

Verified September 30, 2026

Citation
Twist It Up, Inc. v. Annie International, Inc., No. 8:24-cv-00736-DMG-ADS (C.D. Cal. June 27, 2025)
Decided
June 27, 2025

Summary

Chief Judge Dolly M. Gee identified five citations in plaintiff's Opposition to a Motion to Strike that appeared to have been generated by AI. Two citations referred to nonexistent authority, including "Lewis v. CCPOA, 2009 WL 890585 (E.D. Cal. Mar. 31, 2009)" (a Westlaw identifier that does not match the court, date, or proposition cited) and "James v. Claussen, 2022 WL 1120273 (C.D. Cal. Apr. 14, 2022)," which actually points to an appellee's brief in a Texas state criminal manslaughter appeal. A third citation was real but did not support the proposition advanced. The court issued an OSC under Rule 11 directing attorney John D. Tran of Rhema Law Group PC to appear and explain whether AI was used and why the citations were not independently verified.

AI tool:
Unidentified (the June 27, 2025 minutes refer to "invalid case citations generated by the use of an artificial intelligence application")
Sanction amount:
$500
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?

At the June 27, 2025 hearing (minutes, ECF No. 44, entered July 8, 2025), the court imposed Rule 11 sanctions: "The Court imposes Rule 11 sanctions in the amount of $500 on Plaintiffs counsel, the Rhema Law Group PC, for its filing of a brief that contained invalid case citations generated by the use of an artificial intelligence application." The docket records receipt of the $500 on July 18, 2025. The June 26, 2025 order to show cause had also raised the prospect of referral to the Central District's Standing Committee on Discipline.

Why does Twist It Up, Inc. v. Annie International, Inc. matter for law firms using AI?

The OSC is a useful template for how a federal judge handles suspected AI fabrication: the court itself ran down the Westlaw identifiers, found one pointed to a Texas criminal brief, and put the filing attorney and his firm on notice that joint Rule 11 liability and a Standing Committee on Discipline referral were on the table. For a managing partner, the lesson is that “the AI got a Westlaw cite number wrong” reads to a judge as a Rule 11 problem regardless of subjective intent, and the firm carries the exposure alongside the individual lawyer.

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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.

Unverified claims:
  • The cited PDF is the June 26, 2025 order to show cause (ECF No. 42). The sanction itself appears in the June 27, 2025 hearing minutes (ECF No. 44) and their amended version (ECF No. 71), which are not in RECAP; the sanction wording above is quoted from the court's docket text.