Zeus Realty Group LLC v. 1032 N Sycamore Owner LA, LLC
U.S. District Court, Central District of California · C.D. Cal. · California bar guidance
Verified May 5, 2026
- Citation
- Zeus Realty Grp. LLC v. 1032 N Sycamore Owner LA, LLC, No. 2:26-cv-00272-MEMF-RAO, 2026 WL 563023 (C.D. Cal. Feb. 23, 2026)
- Decided
- February 23, 2026
Summary
Attorney Jeff A. Mann of the Law Office of Jeff Mann, representing plaintiff Zeus Realty Group LLC, filed a motion for a temporary restraining order that included citations to nonexistent cases and inaccurate quotations. Defendant's opposition flagged the defective citations and asserted the filings appeared to be a product of artificial intelligence. Judge Maame Ewusi-Mensah Frimpong noted the nonexistent citations in a footnote while denying the motion on jurisdictional grounds.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
The court denied the TRO motion, dismissed the complaint without leave to amend, and dismissed the action without prejudice for lack of jurisdiction (Anti-Injunction Act, Younger abstention, and defective diversity allegations). No monetary sanction was imposed. The court acknowledged the fabricated citations in a footnote but resolved the matter on jurisdictional grounds.
Why does Zeus Realty Group LLC v. 1032 N Sycamore Owner LA, LLC matter for law firms using AI?
Zeus Realty illustrates a recurring pattern: courts increasingly note suspected AI-generated fabrications in passing even when ruling on other grounds. Here, the fabricated citations did not change the outcome, the motion failed on Anti-Injunction Act and Younger abstention grounds, but the court memorialized the defect in a footnote, creating a public record that follows counsel into future matters and renewals.
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.