California · federal district court · 2025

Oneto v. Watson

District Court, N.D. California, 10 October 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · N.D. Cal.

  1. Court. District Court, N.D. CaliforniaCOURT
  2. Level. federal district courtLEVEL
  3. Date. 10 October 2025DATED
  4. Docket. No. 3:22-cv-05206DOCKET
  5. Judge. Araceli Martinez-OlguinJUDGE
  6. Documents. one document, 8 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 92, 10 October 2025 · source · PDF · 8 pages

Docket text. ORDER Sanctioning Plaintiff's Counsel, Edward A. Quesada. Signed by Judge Araceli Martinez-Olguin on October 10, 2025. (amolc3, COURT STAFF) (Filed on 10/10/2025)

90, 91 On July 17, 2025, during the hearing on the parties’ cross-motions for judgment under Federal Rule of Civil Procedure 52, the Court ordered Plaintiff’s counsel, Edward, A. Quesada, to show cause why sanctions or other appropriate disciplinary action should not issue for his inclusion of nonexistent and erroneous case citations in Plaintiff’s brief at Dkt. No.

B. Citations to Fictitious Cases “To start with the obvious, an attorney who submits fake cases clearly has not read those nonexistent cases.” Benjamin v. Costco Wholesale Corp., 779 F.

2023) (“A fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law.”). Quesada’s submission of citations to nonexistent cases, on its own, constitutes a violation of FRCP 11(b). See e.g., Mavy v.

Aug. 14, 2025) (“By repeatedly citing this Court to non-existent ‘cases’ . . . , Counsel failed to conduct any review whatsoever that those cases were valid or that the arguments she was making were legally tenable.”); Allen v. Mercedes-Benz USA, LLC, No.

Cal. June 24, 2025) (“By providing fabricated quotations in the Reply and the Response, the Court finds that [counsel] violated FRCP 11 because he did not act reasonably under the circumstances to ensure that the legal contentions in his brief were accurately representing existing law.”); Wadsworth v. Walmart Inc., 348 F.R.D.

2025) (“Because there is no dispute that Respondents cited fake cases in a signed motion, Respondents’ conduct violates Rule 11(b)(2).”). Here, Quesada’s erroneous citations make clear that he submitted Plaintiff’s brief to the Court without conducting a reasonable inquiry into the validity of the legal authorities cited because he otherwise would have recognized that the cases cited did not exist. In his response to the Court’s order to show cause, Quesada acknowledged that the two cases highlighted by the Court apparently do not exist.

United States District Court Northern District of California Spector and Moffitt v. Whiting-Turner, with non-existent Westlaw citations not repeated here to avoid further fictitious citation). Quesada further acknowledged that he cited in his brief another fake case that the Court had not called out.

Companion Life Ins. Co., with non-existent Westlaw citation not repeated here). Quesada states that he normally downloads and Shepardizes “published” cases cited within his briefs, effectively conceding that he made no effort to review the unpublished cases included within his brief.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

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More from District Court, N.D. California, from California, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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