TQJ, LLC v. Jennifer Esquivel et al.
C.D. California · Feb 12, 2026
What happened in this matter?
The court issued an Order to Show Cause requiring counsel to explain the inclusion of four fabricated legal citations in a reply brief. The court is considering sanctions under Rule 11, 28 U.S.C. § 1927, or its inherent authority, pending counsel's response regarding the origin of the errors and the reliability of other filings.
- Why the court cared
- Fabricated: Case Law | Citation pointed to an unrelated case (United States v. De La Paz) and the purported Muller decision cited (43 F. Supp. 2d 372, 379 (S.D.N.Y. 1999)) could not be located as cited; an older unrelated Muller decision exists but does not support the proposition. || Fabricated: Case Law | Court could not find any case called 'Steele v. County of San Mateo' at the cited 2021 WL and the offered quotation was not found in the cited jurisdiction; closest similar language found only in an unrelated N.D. Ohio case. || Fabricated: Case Law | Court could not locate the cited authority; the 2011 WL citation did not match the cited C.D. Cal. decision and the referenced Lewis case is from a different district and does not discuss the proposition cited. || Fabricated: Case Law | Court was unable to find any case called 'Kogan v. Martin' or the 2019 WL citation offered for the proposition about suggestions and critiques.
- Why it matters now
- Four fabricated cites in one brief means counsel never opened a reporter; mandate primary-source pull-through.
Why this matter is tracked
In TQJ, LLC v. Jennifer Esquivel et al., the U.S. District Court for the Central District of California issued an Order to Show Cause regarding four fabricated legal citations included in the Plaintiff's reply brief. The court identified that the cited cases either did not exist, pointed to unrelated matters, or failed to support the propositions for which they were offered. During a hearing, counsel denied using generative AI and could not explain the presence of the nonexistent authorities. The court expressed concern that counsel failed to review the brief before filing, wasting judicial resources. Counsel was ordered to explain the errors, verify the reliability of other citations in his filings, and outline preventative measures to avoid future occurrences.
Four fabricated cites in one brief means counsel never opened a reporter; mandate primary-source pull-through.
Record details
What the record establishes about AI use
Counsel denied AI use; court noted AI as a possibility.
Order to Show Cause issued February 12, 2026, following a hearing on a motion to dismiss counterclaims.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Citation pointed to an unrelated case (United States v. De La Paz) and the purported Muller decision cited (43 F. Supp. 2d 372, 379 (S.D.N.Y. 1999)) could not be located as cited; an older unrelated Muller decision exists but does not support the proposition.
- Fabricated: Case Law | Court could not find any case called 'Steele v. County of San Mateo' at the cited 2021 WL and the offered quotation was not found in the cited jurisdiction; closest similar language found only in an unrelated N.D. Ohio case.
- Fabricated: Case Law | Court could not locate the cited authority; the 2011 WL citation did not match the cited C.D. Cal. decision and the referenced Lewis case is from a different district and does not discuss the proposition cited.
- Fabricated: Case Law | Court was unable to find any case called 'Kogan v. Martin' or the 2019 WL citation offered for the proposition about suggestions and critiques.
Questions this record answers
- What happened in TQJ, LLC v. Jennifer Esquivel et al.?
- The court issued an Order to Show Cause requiring counsel to explain the inclusion of four fabricated legal citations in a reply brief. The court is considering sanctions under Rule 11, 28 U.S.C. § 1927, or its inherent authority, pending counsel's response regarding the origin of the errors and the reliability of other filings.
- Why does TQJ, LLC v. Jennifer Esquivel et al. matter for legal AI risk?
- Four fabricated cites in one brief means counsel never opened a reporter; mandate primary-source pull-through.
- What does the public record establish about TQJ, LLC v. Jennifer Esquivel et al.?
- 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.
- Which source supports this TQJ, LLC v. Jennifer Esquivel 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.