Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al.
C.D. California · Apr 3, 2026
What happened in this matter?
The court ordered Plaintiffs' counsel to show cause regarding a potentially hallucinated case citation ('Mabee v. County of Orange') found in counsel's briefing. The court required counsel to produce the opinion or explain why sanctions should not be imposed for failing to perform a reasonable inquiry into the validity of legal citations, specifically noting the potential use of artificial intelligence.
- Why the court cared
- The court reasoned that the citation 'Mabee v. County of Orange, 784 F. App'x 585, 588 (9th Cir. 2019)' was non-existent, as the reporter and pincite actually correspond to 'Cochran v. City of Wichita (10th Cir. 2019).' The court concluded that counsel failed to perform a reasonable inquiry into the validity of the authority cited.
- Why it matters now
- Check reporter citations against the actual case name; pincite-only matching is how fabricated cites hide in plain sight.
Why this matter is tracked
In a civil rights action, the court identified a fabricated case citation, 'Mabee v. County of Orange,' included in Plaintiffs' opposition brief. The court determined that the reporter and pincite provided actually correspond to a Tenth Circuit case, 'Cochran v. City of Wichita,' and that no case named 'Mabee v. County of Orange' exists. The court ordered Plaintiffs' counsel to file a sworn declaration within three days to produce the opinion or show cause why sanctions should not be imposed for potential use of artificial intelligence in legal research without reasonable inquiry. The court also deferred ruling on a separate motion for sanctions regarding other alleged misrepresentations in the complaint, pending a hearing.
Check reporter citations against the actual case name; pincite-only matching is how fabricated cites hide in plain sight.
Record details
What the record establishes about AI use
Court explicitly mentions potential use of artificial intelligence.
The court issued an Order to Show Cause regarding a fabricated citation while simultaneously granting a motion to dismiss and deferring ruling on a separate motion for sanctions.
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 cited a purported Ninth Circuit case 'Mabee v. County of Orange, 784 F. App'x 585, 588 (9th Cir. 2019)'; the court found no such case and that the reporter/pincite instead corresponds to Cochran v. City of Wichita (10th Cir.). Court ordered counsel to produce the Mabee opinion or show cause.
Questions this record answers
- What happened in Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al.?
- The court ordered Plaintiffs' counsel to show cause regarding a potentially hallucinated case citation ('Mabee v. County of Orange') found in counsel's briefing. The court required counsel to produce the opinion or explain why sanctions should not be imposed for failing to perform a reasonable inquiry into the validity of legal citations, specifically noting the potential use of artificial intelligence.
- Why does Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al. matter for legal AI risk?
- Check reporter citations against the actual case name; pincite-only matching is how fabricated cites hide in plain sight.
- What does the public record establish about Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al. 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.