Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al.
D. Utah · Dec 4, 2025
What happened in this matter?
The court sanctioned defense counsel for violating Rule 11(b)(2) by including hallucinated case citations in an opposition brief. The court rejected counsel's reliance on a colleague's work as a defense, emphasizing the non-delegable duty of reasonable inquiry. The court ordered counsel to read all authorities cited in the court's order and file a certification of compliance within 30 days.
- Why the court cared
- Fabricated: Case Law | Opposition cited Rawson v. Mathews, 212 P.3d 752, 756–57 (Utah 2009) to support equitable tolling; court determined the opinion does not exist and called it a hallucinated case. || Fabricated: Case Law | Opposition cited Equilon Enters. v. Ford Motor Co., 2010 UT 44, ¶ 37 for equitable tolling; court found the opinion does not exist and treated it as a fabricated citation. || False Quotes: Case Law | Opposition attributed language to Agency Holding Corp. v. Malley-Duff & Assocs., 483 U.S. 143 (1987) that does not appear in the opinion; court treated this as a false quotation/misattribution.
- Why it matters now
- Courts now order counsel to read and certify every cited authority — build that step into filing checklists before the court does it for you.
Why this matter is tracked
In Black Oak Capital BOCA, LLC v. Paul Evans, LLC, the U.S. District Court for the District of Utah addressed a Rule 11 motion for sanctions against defense counsel for submitting filings containing hallucinated case law. Counsel cited two non-existent cases, Rawson v. Mathews and Equilon Enters. v. Ford Motor Co., to support an equitable tolling argument, and misattributed language to Agency Holding Corp. v. Malley-Duff & Assocs. Counsel attributed the errors to reliance on a colleague's writings. The court found these actions violated Rule 11(b)(2) by failing to conduct a reasonable inquiry. As a sanction, the court ordered counsel to read all authorities cited in the court's memorandum decision and file a certification of compliance within 30 days.
Courts now order counsel to read and certify every cited authority — build that step into filing checklists before the court does it for you.
Record details
What the record establishes about AI use
Court refers to AI hallucination as the source of the fake cases.
The court issued a memorandum decision and order granting in part and denying in part the plaintiffs' motion for Rule 11 sanctions following the submission of an opposition brief containing fabricated legal authorities.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Opposition cited Rawson v. Mathews, 212 P.3d 752, 756–57 (Utah 2009) to support equitable tolling; court determined the opinion does not exist and called it a hallucinated case.
- Fabricated: Case Law | Opposition cited Equilon Enters. v. Ford Motor Co., 2010 UT 44, ¶ 37 for equitable tolling; court found the opinion does not exist and treated it as a fabricated citation.
- False Quotes: Case Law | Opposition attributed language to Agency Holding Corp. v. Malley-Duff & Assocs., 483 U.S. 143 (1987) that does not appear in the opinion; court treated this as a false quotation/misattribution.
Questions this record answers
- What happened in Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al.?
- The court sanctioned defense counsel for violating Rule 11(b)(2) by including hallucinated case citations in an opposition brief. The court rejected counsel's reliance on a colleague's work as a defense, emphasizing the non-delegable duty of reasonable inquiry. The court ordered counsel to read all authorities cited in the court's order and file a certification of compliance within 30 days.
- Why does Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al. matter for legal AI risk?
- Courts now order counsel to read and certify every cited authority — build that step into filing checklists before the court does it for you.
- What does the public record establish about Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al.?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.