TQJ, LLC v. Jennifer Esquivel et al.
C.D. California · Feb 12, 2026
- Jurisdiction
- federal
- Court
- C.D. California
- Record ID
- tqj-llc-v-jennifer-esquivel-et-al-2026-02-12
- Observed outcome
- The court issued an Order to Show Cause requiring counsel to explain the fabricated citations and demonstrate the reliability of other filings.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Four fabricated cites in one brief means counsel never opened a reporter; mandate primary-source pull-through.
Failure modes and consequences
- Fabricated_case_law
- Lack_of_citation_verification
- Fake Citations
- Fabricated Quotes
- Ip
- Trial
- AI attribution
- Implied
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- Order to Show Cause issued February 12, 2026, following a hearing on a motion to dismiss counterclaims.
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 denied AI use; court noted AI as a possibility.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.