Gharavi v. Google LLC
N.D. California · Jan 12, 2026
What happened in this matter?
The court denied the motion for sanctions, ruling that counsel's reliance on Bloomberg Law for a fabricated case citation was inadvertent and did not constitute bad faith or recklessness. The court determined the error was a harmless mistake that did not warrant sanctions.
- Why the court cared
- Fabricated: Case Law | Counsel included a non-existent Wisconsin case in a sworn declaration; court found counsel relied on Bloomberg Law and the error was inadvertent and not in bad faith.
- Why it matters now
- Reliance on Bloomberg Law defeats bad-faith findings, but only if the error is isolated and acknowledged.
Why this matter is tracked
In a discovery dispute, petitioner Nima Gharavi moved for sanctions against respondent's counsel, Torryn T. Rodgers, after she submitted a declaration containing a non-existent Wisconsin criminal case citation. Rodgers stated she relied on Bloomberg Law, which provided the incorrect case information. Upon discovering the error, counsel promptly rectified the declaration. The court found that the inclusion of the fabricated citation was an inadvertent error resulting from reliance on a trusted legal research tool, rather than an act of recklessness or bad faith. Consequently, the court denied the motion for sanctions, noting that the error was harmless and did not impact the underlying motions. The court also denied Gharavi's motion to strike the declaration, finding the testimony admissible.
Reliance on Bloomberg Law defeats bad-faith findings, but only if the error is isolated and acknowledged.
Record details
What the record establishes about AI use
Counsel declared reliance on Bloomberg Law for the incorrect citation.
The court addressed multiple discovery-related motions, including a motion to compel, a motion to strike, and a motion for sanctions, ultimately denying the motion for sanctions and the motion to strike, while granting the motion to strike filed by the respondent.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Counsel included a non-existent Wisconsin case in a sworn declaration; court found counsel relied on Bloomberg Law and the error was inadvertent and not in bad faith.
Questions this record answers
- What happened in Gharavi v. Google LLC?
- The court denied the motion for sanctions, ruling that counsel's reliance on Bloomberg Law for a fabricated case citation was inadvertent and did not constitute bad faith or recklessness. The court determined the error was a harmless mistake that did not warrant sanctions.
- Why does Gharavi v. Google LLC matter for legal AI risk?
- Reliance on Bloomberg Law defeats bad-faith findings, but only if the error is isolated and acknowledged.
- What does the public record establish about Gharavi v. Google LLC?
- 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 Gharavi v. Google LLC 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.