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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
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That Xiong v. Minga Wofford (2)
E.D. California · May 21, 2026
CA / federalEditorial impact: lowfake citationshabeastrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Petitioner's brief cited 'G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025)'; Court found the Westlaw citation corresponded to a different real case, indicating a hallucinated citation likely from GenAI. Outcome: No Sanctions in circumstances. Order to Show Cause is here. The court concluded:"After careful consideration, including the involvement of a law student at the beginning of their legal career and for the reasons stated above, the Court exercises its discretion to discharge the OSC (ECF No.…
- Why the court cared
- The record concerns whether authorities presented to the decision-maker existed and could be verified. The tracked outcome is No Sanctions in circumstances; the linked source controls the precise reasoning.
- Why it matters now
- This matter connects fake citations and habeas involving ChatGPT with No Sanctions in circumstances in E.D. California, making it a concrete reference point for verification, supervision, and response controls.
Why this matter is tracked
Fabricated: Case Law | Petitioner's brief cited 'G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025)'; Court found the Westlaw citation corresponded to a different real case, indicating a hallucinated citation likely from GenAI. Outcome: No Sanctions in circumstances. Order to Show Cause is here. The court concluded:"After careful consideration, including the involvement of a law student at the beginning of their legal career and for the reasons stated above, the Court exercises its discretion to discharge the OSC (ECF No. 49) and declines to impose sanctions on Petitioner’s counsel Cummings or law student [XX] for counsel’s failure to fully comply with the Court’s January 13, 2026 order. The Court repeats its admonishment that while AI and generative AI tools can assist counsel and parties, these tools must be used responsibly. They should not be used to verify legal authorityand citations, especially when generative AI tools were used to generate or identify the legal authority and citations being checked."
Operational lesson
This matter connects fake citations and habeas involving ChatGPT with No Sanctions in circumstances in E.D. California, making it a concrete reference point for verification, supervision, and response controls.
Record details
CaliforniaSingle-state evidence scope
CourtE.D. California
Jurisdictionfederal
Circuit9th Circuit
DateMay 21, 2026
CH
AI toolChatGPT
Party typeLawyer
OutcomeNo Sanctions in circumstances
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
ChatGPT is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
No Sanctions in circumstances
Correction behavior
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 | Petitioner's brief cited 'G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025)'; Court found the Westlaw citation corresponded to a different real case, indicating a hallucinated citation likely from GenAI.
- Fabricated: Case Law | Court previously identified a citation in Petitioner's reply to 'Phan v. Barr, No. 1:19-cv-01451, 2019 WL 7758773 (E.D. Cal. Dec. 20, 2019)' that it could not locate and which appeared to be hallucinated.
- Fabricated: Case Law | Court previously identified a citation in Petitioner's reply to 'Flores v. Barr, No. 1:20-cv-00491, 2020 WL 1939565 (E.D. Cal. Apr. 22, 2020)' that it could not locate and which appeared to be hallucinated.
Questions this record answers
- What happened in That Xiong v. Minga Wofford (2)?
- Fabricated: Case Law | Petitioner's brief cited 'G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025)'; Court found the Westlaw citation corresponded to a different real case, indicating a hallucinated citation likely from GenAI. Outcome: No Sanctions in circumstances. Order to Show Cause is here. The court concluded:"After careful consideration, including the involvement of a law student at the beginning of their legal career and for the reasons stated above, the Court exercises its discretion to discharge the OSC (ECF No.…
- Why does That Xiong v. Minga Wofford (2) matter for legal AI risk?
- This matter connects fake citations and habeas involving ChatGPT with No Sanctions in circumstances in E.D. California, making it a concrete reference point for verification, supervision, and response controls.
- What does the public record establish about That Xiong v. Minga Wofford (2)?
- 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 That Xiong v. Minga Wofford (2) 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.