Tekoma Chaney v. Transdev Services Inc. et al.
C.D. California · Apr 28, 2026
- Jurisdiction
- federal
- Court
- C.D. California
- Record ID
- tekoma-chaney-v-transdev-services-inc-et-al-2026-04-28
- Observed outcome
- The court granted summary judgment for defendants and imposed a $2,500 monetary sanction on plaintiff's counsel, plus a mandatory reporting requirement to all judges in the district.
- Known monetary consequence
- $2,500
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fake Citations
- Civil Rights
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- LexisNexis+ (Protégé)
- Known monetary consequence
- $2,500
- Procedural posture
- 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.
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
Counsel admitted to using LexisNexis+ and its Protégé feature.
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
- Implement mandatory verification protocols for all citations generated by AI research tools.
- Ensure all disclosures regarding AI use are transparent, timely, and filed as standalone documents rather than buried in other filings.
- Disclose all instances of AI-generated errors immediately upon discovery to avoid findings of bad faith.
- Maintain a record of all AI-assisted research and the verification steps taken for each citation.