Published opinion, 10 September 2026 · source · PDF · 12 pages
Davis was listed as counsel of record on the front page of the petition with his State Bar number and contact information. Mejia signed the petition.1 The petition’s table of authorities listed four suspicious cases that appeared to have been fabricated2 by generative AI: Dowds v. Basehore (2018) 26 Cal.App.5th 265, In re Gruntz (9th Cir.
2002) 287 B.R. 546 does not exist; the citation leads to In re Munoz. There is a party involved with the last name Ruvacalba, but it is spelled differently than Rubalcaba.
However, it was cited for the proposition a “trial court 1 Mejia’s State Bar number appears nowhere in the petition, a violation of California Rules of Court, rule 2.111(1). 2 A fabricated or hallucinated citation is a product of generative AI tools that create fake legal authority consisting of citations to nonexistent cases, quotes that do not appear in the cited cases, or cases cited for legal propositions entirely different from those represented. (See generally Noland v.
(2025) 114 Cal.App.5th 426, 430 (Noland).) 3 maintains no judicial discretion to enforce a void judgment.” There was no pinpoint cite for the assertion, and the case does not stand for the proposition asserted. On May 27, 2026, we issued an order to show cause why sanctions should not be imposed against Davis and Mejia for use of fabricated quotations and erroneous statements of law in violation of Business and Professions Code section 6068, subdivision (d), State Bar Rules of Professional Conduct, rule 3.3(a)(1) and (2), and California Rules of Court, rules 2.30(b), and 8.891(e)(1)(B). On July 1, 2026, Davis and Mejia filed a joint brief supported by a declaration from each attorney.
Mejia accepts responsibility for violating California Rules of Court, rule 8.1115 but contends he did not violate Business and Professions Code section 6068, 4 subdivision (d), because he did not intend to mislead the court or knowingly present false legal authority. He also argues he did not violate State Bar Rules of Professional Conduct, rule 3.3(a)(1) because he did not knowingly make a false statement of law or knowingly submit fabricated authority to the court. Mejia attributes his failure to verify the authorities to being under significant time constraints due to the emergency nature of the petition and his client’s pending eviction.
Rules of Court, rule 8.891(e)(1)(B).) California Rules of Court, rule 2.30(a) and (b) also permit the appellate division in a civil proceeding to order an attorney to pay reasonable monetary sanctions to the court for failure without good cause to comply with applicable rules. “Relying on fabricated legal authority is sanctionable.......... An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” (Noland, supra, 114 Cal.App.5th at p.
Just as a competent attorney would very carefully check the veracity and accuracy of all case citations in any pleading, motion, response, reply, or other paper prepared by a law clerk, intern, or other attorney before it is filed, the same holds true when attorneys utilize AI or any other form of technology.” (Id. at p. 446 (cleaned up).) In Noland, the court sanctioned appellant’s counsel $10,000 for relying on AI hallucinated citations. (Id. at p.
(See Alvarez, supra, 114 Cal.App.5th at p. 1120 [appellate counsel sanctioned $1,500 for including fictitious quotation, citing nonexistent case and two cases not 6 addressing issues for which they were cited]; Schlichter v. Kennedy (2025) 116 Cal.App.5th 24, 34 [appellate counsel sanctioned $1,750 for opening brief and writ petition containing hallucinated citations]; Shayan v.