Christina Garcia v. Atwater Elementary Teachers Association
California PERB · Dec 15, 2025
What happened in this matter?
The California PERB issued a formal warning to a pro se litigant for submitting an appeal containing multiple AI-hallucinated legal citations. Although the Board determined the conduct constituted bad faith, it declined to impose monetary sanctions in this instance, establishing a precedent that future submissions of fabricated authority will face stricter penalties.
- Why the court cared
- Fabricated: Case Law | Appeal repeatedly cited a nonexistent PERB decision 'Teamsters Local 150 (PERB Dec. No. 2789)'; the Board found the decision does not exist and that the citation was fabricated via AI. || Fabricated: Case Law | Appeal repeatedly cited a nonexistent PERB decision 'SEIU Local 721 (PERB Dec. No. 2544)'; the Board found the decision does not exist and that the citation was fabricated via AI. || Fabricated: Case Law | Appeal repeatedly cited a nonexistent PERB decision 'UTLA (PERB Dec. No. 2255)'; the Board found the decision does not exist and that the citation was fabricated via AI.
- Why it matters now
- This record documents a Pro Se Litigant filing issue in California PERB, with the listed outcome: Warning.
Why this matter is tracked
In an appeal before the California Public Employment Relations Board (PERB), a pro se litigant, Christina Garcia, submitted filings containing multiple fabricated legal citations generated by AI. The Board identified that the cited PERB decisions did not exist. While the Board found that Garcia pursued her appeal in bad faith by failing to verify the AI-generated content, it declined to impose monetary sanctions, citing her pro se status and the fact that this was a matter of first impression for the agency. The Board issued a formal warning, putting all future litigants and representatives on notice that the submission of fabricated legal authority will warrant serious consequences, including potential monetary sanctions and reporting to the State Bar for attorneys.
This record documents a Pro Se Litigant filing issue in California PERB, with the listed outcome: Warning.
Record details
What the record establishes about AI use
The litigant admitted to using AI but the specific tool was not named.
The case reached the Board on appeal from a dismissal of an unfair practice charge by the Office of the General Counsel. The Board issued an Order to Show Cause regarding the fabricated citations before issuing this final decision.
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 | Appeal repeatedly cited a nonexistent PERB decision 'Teamsters Local 150 (PERB Dec. No. 2789)'; the Board found the decision does not exist and that the citation was fabricated via AI.
- Fabricated: Case Law | Appeal repeatedly cited a nonexistent PERB decision 'SEIU Local 721 (PERB Dec. No. 2544)'; the Board found the decision does not exist and that the citation was fabricated via AI.
- Fabricated: Case Law | Appeal repeatedly cited a nonexistent PERB decision 'UTLA (PERB Dec. No. 2255)'; the Board found the decision does not exist and that the citation was fabricated via AI.
Questions this record answers
- What happened in Christina Garcia v. Atwater Elementary Teachers Association?
- The California PERB issued a formal warning to a pro se litigant for submitting an appeal containing multiple AI-hallucinated legal citations. Although the Board determined the conduct constituted bad faith, it declined to impose monetary sanctions in this instance, establishing a precedent that future submissions of fabricated authority will face stricter penalties.
- Why does Christina Garcia v. Atwater Elementary Teachers Association matter for legal AI risk?
- This record documents a Pro Se Litigant filing issue in California PERB, with the listed outcome: Warning.
- What does the public record establish about Christina Garcia v. Atwater Elementary Teachers Association?
- 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 Christina Garcia v. Atwater Elementary Teachers Association 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.