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AI VORTEXLEGAL AI RISK INTELLIGENCE
CASE BRIEF / REVIEW PACKETAV-CB-0D4JII8Generated September 11, 2026Evidence checked Sep 11, 2026
TRACKED PUBLIC MATTER

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
ADVISOR READOUT

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.

Why the decision-maker 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.

RECORDED ISSUES

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.
PRIMARY SOURCE

Damien Charlotin case archive

Publisher document archive. The recorded document is hosted in the upstream publisher archive.

Open underlying source

A recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.

EVIDENCE BOUNDARY

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).

PRACTICAL REVIEW IMPLICATIONS

Controls suggested by the public record

  1. Verify each cited authority, quotation, and proposition against the underlying source before filing.