Daniel James Cummins v. Moises Becerra
E.D. California · Feb 9, 2026
- Jurisdiction
- federal
- Court
- E.D. California
- Record ID
- daniel-james-cummins-v-moises-becerra-2026-02-09
- Observed outcome
- The court issued an Order to Show Cause requiring counsel to justify the inclusion of hallucinated citations and the unauthorized appearance of a law student.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued an Order to Show Cause requiring counsel to explain the inclusion of AI-hallucinated case citations in briefing and the unauthorized appearance of a law student. The court found the citations lacked existence or relevance, mirroring patterns of AI-generated content, and determined that a prior errata filing was insufficient to address the scope of the errors.
Fabricated: Case Law | Petitioner's reply included a citation to 'Vuong' which, per petitioner's errata and the court, does not appear in publicly available legal databases and was identified as erroneous. || Fabricated: Case Law | Petitioner's reply included a citation to 'Arellano' which, per petitioner's errata and the court, does not appear in publicly available legal databases and was identified as erroneous. || Fabricated: Case Law | Petitioner's reply included a citation to 'Calderon' which, per petitioner's errata and the court, does not appear in publicly available legal databases and was identified as erroneous. || Fabricated: Case Law | Petitioner's reply included a citation to 'Pham' which, per petitioner's errata and the court, does not appear in publicly available legal databases and was identified as erroneous. || Fabricated: Case Law | The motion and reply contain numerous other citations that either do not exist or do not support the propositions for which they were offered; the court found these bear the hallmarks of AI-generated 'hallucinated' cases.
Filing an errata does not cure a brief full of hallucinations; courts still issue OSCs on the underlying AI misuse.
Failure modes and consequences
- Fake Citations
- Habeas
- Trial
- Ordered To Show Cause
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order to Show Cause issued February 9, 2026, following a motion to enforce and modify habeas relief.
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 court identified citations as bearing hallmarks of AI tools.
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.