Segui v. Moniz
D. Arizona · Mar 24, 2026
What happened in this matter?
The Court ordered Plaintiffs' counsel to show cause why sanctions should not be imposed under Rule 11 for citing a nonexistent case. The Court identified the citation as fabricated and noted that the legal proposition it purportedly supported was also incorrect under Arizona law.
- Why the court cared
- The Court reasoned that citing nonexistent authority violates the duty under Rule 11(b)(2) to ensure legal citations are warranted by existing law and the product of reasonable inquiry. It explicitly stated that the fabrication of citations, whether via AI or otherwise, undermines judicial integrity.
- Why it matters now
- A single fabricated state-court cite triggers Rule 11 show-cause — verify every cite against the official reporter before filing.
Why this matter is tracked
In a civil rights action, the U.S. District Court for the District of Arizona identified that Plaintiffs' counsel cited a nonexistent Arizona appellate decision, 'Barker v. Brown & Brown,' to support a statute of limitations argument. The Court noted that the citation was fabricated and the legal proposition cited was incorrect. While the Court denied a separate motion for sanctions filed by a defendant due to procedural deficiencies, it acted sua sponte under Federal Rule of Civil Procedure 11(c)(3). The Court ordered Plaintiffs' counsel to show cause in writing why sanctions should not be imposed for the citation of nonexistent authority, emphasizing that such conduct undermines the integrity of the judicial process regardless of whether it resulted from artificial intelligence.
A single fabricated state-court cite triggers Rule 11 show-cause — verify every cite against the official reporter before filing.
Record details
What the record establishes about AI use
The court mentions AI as a potential source of the fabrication.
Order to Show Cause issued sua sponte by the District Court following a motion to dismiss.
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 | Plaintiffs' counsel cited a nonexistent Arizona appellate decision 'Barker v. Brown & Brown, 210 Ariz. 321, 110 P.3d 1011 (Ct. App. 2005)'; the Court found the citation fabricated, noted the legal proposition was incorrect, and ordered counsel to show cause under Rule 11.
Questions this record answers
- What happened in Segui v. Moniz?
- The Court ordered Plaintiffs' counsel to show cause why sanctions should not be imposed under Rule 11 for citing a nonexistent case. The Court identified the citation as fabricated and noted that the legal proposition it purportedly supported was also incorrect under Arizona law.
- Why does Segui v. Moniz matter for legal AI risk?
- A single fabricated state-court cite triggers Rule 11 show-cause — verify every cite against the official reporter before filing.
- What does the public record establish about Segui v. Moniz?
- 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 Segui v. Moniz 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.