EFD USA, INC., et al. v. Band Pro Film and Digital, Inc., et al.
CA California · Feb 18, 2026
- Jurisdiction
- state
- Court
- CA California
- Record ID
- efd-usa-inc-et-al-v-band-pro-film-and-digital-inc-et-al-2026-02-18
- Observed outcome
- The court affirmed the underlying judgment and ordered attorney David E. Azar to pay $900 in sanctions to the clerk of the court.
- Known monetary consequence
- $900
Why this matter warrants attention
The court sanctioned attorney David E. Azar $900 for filing appellate briefs containing fabricated quotations and inaccurate citations. The court found that counsel's use of an AI system to trim word counts resulted in the silent alteration of legal authorities, which counsel failed to verify before filing.
Fabricated: Case Law | Appellant quoted Lilienthal as stating tests for distinct claims ('(1) times of services performed; (2) specific obligations involved; and (3) resulting damages'), but the quotation does not appear in Lilienthal and the case does not address settlement offsets. || Fabricated: Case Law | Appellant quoted Rudick as stating that failure to respond waives an objection; the cited Rudick decision does not include that quotation. || Fabricated: Case Law | Appellant attributed a quotation about using extrinsic evidence to interpret a settlement reached in mediation (with arbitration clause) to Riverisland; the quoted language does not appear in Riverisland. || Fabricated: Case Law | Appellant attributed an objective-contract interpretation quotation to Leaf v. City of San Mateo; the Leaf opinion does not contain the quoted language and did not involve a contested contract. || Fabricated: Case Law | Appellant cited Milstein for the proposition 'a judgment by default admits all material allegations of the complaint,' but Milstein does not contain that language as quoted. || Fabricated: Case Law | Multiple additional fabricated quotations and inaccurate descriptions of legal authorities appeared across the opening and reply briefs, attributed by counsel to use of an AI system that altered citations during word-count reduction.
AI word-count trimmers silently rewrite quotations; ban their use on filed briefs or force a final primary-source diff.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Contract
- Appellate
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified AI system
- Known monetary consequence
- $900
- Procedural posture
- Appellate review of a trial court judgment and order, resulting in an order to show cause regarding sanctions for frivolous appellate briefing.
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
Counsel admitted to using an unidentified AI system to shorten the draft.
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.
- Use only approved research and drafting tools for legal work.
- Retain a matter-level record of source checks and corrections.