Tekoma Chaney v. Transdev Services Inc. et al.
C.D. California · Apr 28, 2026
What happened in this matter?
The court sanctioned plaintiff's counsel $2,500 for bad faith conduct after he submitted three instances of hallucinated case law generated by LexisNexis+ (Protégé). Additionally, the court ordered counsel to file and distribute a declaration detailing his AI misuse and the court's bad faith findings to all judges in the Central District of California.
- Why the court cared
- The court found that the prevalence of AI-related sanctions put counsel on notice of the duty to verify citations. It determined that counsel's failure to verify, coupled with his attempts to bury the admission of AI use within improper sur-responses and his failure to disclose all instances of the fabricated citation, demonstrated bad faith warranting monetary and reporting sanctions.
- Why it matters now
- This matter connects fake citations and civil rights involving LexisNexis+ (Protégé) with Monetary Sanction; Reporting to other courts in C.D. California, making it a concrete reference point for verification, supervision, and response controls.
Why this matter is tracked
In a civil rights action, the court sanctioned plaintiff's counsel, Gavril T. Gabriel, for submitting briefs containing fabricated case law generated by LexisNexis+ (Protégé). Counsel cited 'In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015)' in three separate instances across two opposition briefs. The court determined the case was non-existent and that counsel's failure to verify citations, combined with attempts to obfuscate the misuse of generative AI in subsequent declarations, constituted bad faith. The court imposed a $2,500 monetary sanction and ordered counsel to report the misconduct and the court's bad faith findings to every judge before whom he currently appears in the Central District of California.
This matter connects fake citations and civil rights involving LexisNexis+ (Protégé) with Monetary Sanction; Reporting to other courts in C.D. California, making it a concrete reference point for verification, supervision, and response controls.
Record details
What the record establishes about AI use
Counsel admitted to using LexisNexis+ and its Protégé feature.
The court granted defendants' motions for summary judgment and simultaneously issued an order imposing sanctions on plaintiff's counsel following an order to show cause.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Attributed 'In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015)' as authority in Plaintiff's Opposition to Ogilvie's MSJ (p.17); Court found the case fabricated and the reporter/pincite corresponds to an unrelated real case.
- Fabricated: Case Law | Same fabricated citation used twice in Plaintiff's Opposition to Transdev's MSJ (Opp'n TMSJ pp.15–16); Court noted counsel failed to disclose these additional uses in initial declaration.
- Fabricated: Case Law | Third instance of the same fabricated authority appearing in briefing; Court treated repeated uses as aggravating factor in finding bad faith and imposing monetary and reporting sanctions.
Questions this record answers
- What happened in Tekoma Chaney v. Transdev Services Inc. et al.?
- The court sanctioned plaintiff's counsel $2,500 for bad faith conduct after he submitted three instances of hallucinated case law generated by LexisNexis+ (Protégé). Additionally, the court ordered counsel to file and distribute a declaration detailing his AI misuse and the court's bad faith findings to all judges in the Central District of California.
- Why does Tekoma Chaney v. Transdev Services Inc. et al. matter for legal AI risk?
- This matter connects fake citations and civil rights involving LexisNexis+ (Protégé) with Monetary Sanction; Reporting to other courts in C.D. California, making it a concrete reference point for verification, supervision, and response controls.
- What does the public record establish about Tekoma Chaney v. Transdev Services Inc. 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 Tekoma Chaney v. Transdev Services Inc. 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.