Schlichter v. Kennedy
CA California · Nov 17, 2025
- Jurisdiction
- state
- Court
- CA California
- Record ID
- schlichter-v-kennedy-2025-11-17
- Observed outcome
- The court imposed a $1,750 monetary sanction payable to the court and directed the Clerk to notify the State Bar of California.
- Known monetary consequence
- $1,750
Why this matter warrants attention
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.
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.
A small monetary sanction plus bar referral is the new baseline — the dollar amount is irrelevant, the referral is the career risk.
Failure modes and consequences
- Hallucinated_case_law
- Failure_to_verify_citations
- Lack_of_candor_with_court
- Fake Citations
- Bar Referral
- Appellate
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $1,750
- Procedural posture
- 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.
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
The source identifies the tool only as 'AI' or 'generative AI'.
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.
- Train lawyers and staff to identify and verify generated legal content.
- Retain a matter-level record of source checks and corrections.