Schlichter v. Kennedy
CA California · Nov 17, 2025
What happened in this matter?
The court sanctioned attorney Jeffrey Dean Grotke $1,750 and ordered a State Bar referral for filing briefs containing fabricated legal citations. The court rejected Grotke's claim that the errors were clerical, finding he failed to verify his work and violated California Rules of Court, rule 8.204(a)(1)(B) by failing to support points with real legal authority.
- Why the court cared
- Fabricated: Case Law | Cited nonexistent 'Estate of Layton (1938) 29 Cal.App.2d 599' for a proposition about life tenants; court found no such reporter/page case and the actual Estate of Layton cases do not support the proposition. || Fabricated: Case Law | Cited nonexistent 'Riddle v. Harmon (1865) 5 Cal. 491, 494' as recognizing a life-estate vs cash-assets distinction; court found that citation does not exist and the real Riddle v. Harmon (1980) concerns joint tenancy termination. || Fabricated: Case Law | Cited nonexistent 'Estate of Kraus (1970) 8 Cal.App.3d 429' for the proposition that assets not in pleadings fall outside probate court jurisdiction; court found the cited reporter/page does not exist and the actual Estate of Kraus (2010) does not support that proposition. || Fabricated: Case Law | Cited nonexistent 'Estate of Hermon (1973) 16 Cal.App.3d 421' to claim courts construe wills in light of equitable considerations; court found the cited reporter/page does not exist and the actual Estate of Hermon (1995) does not contain 'equitable' analysis.
- Why it matters now
- A small monetary sanction plus bar referral is the new baseline — the dollar amount is irrelevant, the referral is the career risk.
Why this matter is tracked
The California Court of Appeal sanctioned attorney Jeffrey Dean Grotke for including fabricated legal citations in a writ petition and an opening brief. The court identified four nonexistent cases cited by Grotke, noting that the volume and page numbers corresponded to unrelated cases, and the actual cases with those names did not support the propositions for which they were cited. Grotke admitted to using AI in preparing his filings but claimed the errors were clerical. The court found Grotke's explanations lacked credibility, concluding he failed to verify his citations and violated California Rules of Court, rule 8.204(a)(1)(B). The court imposed a $1,750 monetary sanction and ordered a referral to the State Bar of California.
A small monetary sanction plus bar referral is the new baseline — the dollar amount is irrelevant, the referral is the career risk.
Record details
What the record establishes about AI use
The source identifies the tool only as 'AI' or 'generative AI'.
The court issued an order to show cause regarding sanctions for fabricated legal authority, held a hearing on November 4, 2025, and issued a final order imposing sanctions on November 17, 2025.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Cited nonexistent 'Estate of Layton (1938) 29 Cal.App.2d 599' for a proposition about life tenants; court found no such reporter/page case and the actual Estate of Layton cases do not support the proposition.
- Fabricated: Case Law | Cited nonexistent 'Riddle v. Harmon (1865) 5 Cal. 491, 494' as recognizing a life-estate vs cash-assets distinction; court found that citation does not exist and the real Riddle v. Harmon (1980) concerns joint tenancy termination.
- Fabricated: Case Law | Cited nonexistent 'Estate of Kraus (1970) 8 Cal.App.3d 429' for the proposition that assets not in pleadings fall outside probate court jurisdiction; court found the cited reporter/page does not exist and the actual Estate of Kraus (2010) does not support that proposition.
- Fabricated: Case Law | Cited nonexistent 'Estate of Hermon (1973) 16 Cal.App.3d 421' to claim courts construe wills in light of equitable considerations; court found the cited reporter/page does not exist and the actual Estate of Hermon (1995) does not contain 'equitable' analysis.
Questions this record answers
- What happened in Schlichter v. Kennedy?
- The court sanctioned attorney Jeffrey Dean Grotke $1,750 and ordered a State Bar referral for filing briefs containing fabricated legal citations. The court rejected Grotke's claim that the errors were clerical, finding he failed to verify his work and violated California Rules of Court, rule 8.204(a)(1)(B) by failing to support points with real legal authority.
- Why does Schlichter v. Kennedy matter for legal AI risk?
- A small monetary sanction plus bar referral is the new baseline — the dollar amount is irrelevant, the referral is the career risk.
- What does the public record establish about Schlichter v. Kennedy?
- 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 Schlichter v. Kennedy 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.