Twist It Up, Inc. v. Annie International, Inc.
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 5, 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:
- Unspecified generative AI
- Sanction amount:
- $500
What sanction did the court impose?
Following the June 27, 2025 hearing, the court imposed a $500 monetary sanction on Rhema Law Group PC. The OSC 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.
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.
- Final $500 sanction amount and June 27, 2025 entry date drawn from Charlotin's compilation; the verified PDF on file is the June 26, 2025 OSC (Doc. 42), not the post-hearing sanctions order itself.