Christina Garcia v. Atwater Elementary Teachers Association
California PERB · Dec 15, 2025
- Jurisdiction
- state
- Court
- California PERB
- Record ID
- christina-garcia-v-atwater-elementary-teachers-association-2025-12-15
- Observed outcome
- The Board denied the appeal and issued a formal warning regarding the use of AI-generated fabricated legal citations.
- Known monetary consequence
- $0
Why this matter warrants attention
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.
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.
This record documents a Pro Se Litigant filing issue in California PERB, with the listed outcome: Warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Administrative
- Trial
- Warning
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $0
- Procedural posture
- 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.
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
The litigant admitted to using AI but the specific tool was not named.
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.