Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al.
D. Utah · Dec 4, 2025
- Jurisdiction
- federal
- Court
- D. Utah
- Record ID
- black-oak-capital-boca-llc-v-paul-evans-llc-et-al-2025-12-04
- Observed outcome
- The court granted the motion for sanctions in part, ordering counsel to read all authorities cited in the court's memorandum decision and file a certification of compliance within 30 days.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Courts now order counsel to read and certify every cited authority — build that step into filing checklists before the court does it for you.
Failure modes and consequences
- Hallucinated_case_law
- False_quotations
- Failure_to_verify_citations
- Improper_delegation_of_research
- Fake Citations
- Fabricated Quotes
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Court refers to AI hallucination as the source of the fake cases.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.
- Assign a responsible reviewer for AI-assisted research and drafting.