Modern Floor Specialists, Inc. et al. v. City of Los Angeles et al.
C.D. California · Apr 3, 2026
- Jurisdiction
- federal
- Court
- C.D. California
- Record ID
- modern-floor-specialists-inc-et-al-v-city-of-los-angeles-et-al-2026-04-03
- Observed outcome
- The court ordered counsel to show cause regarding the fabricated citation and set a hearing for April 14, 2026.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Check reporter citations against the actual case name; pincite-only matching is how fabricated cites hide in plain sight.
Failure modes and consequences
- Fake Citations
- Civil Rights
- Trial
- Ordered To Show Cause
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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
Court explicitly mentions potential use of artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.