Zhdanovich-Doty v. Provident Life and Accident Insurance Company
N.D. California · Jun 22, 2026
What happened in this matter?
The court issued a warning to plaintiff's counsel after identifying that counsel submitted a fabricated case citation, likely generated by an artificial intelligence tool. The court explicitly cautioned that any future submission of nonexistent authority may result in further sanctions.
- Why the court cared
- The court reasoned that the cited case did not exist and that the language attributed to it was fabricated, concluding that counsel likely relied on an AI tool to generate the authority.
- Why it matters now
- This case highlights the judicial response to the submission of AI-hallucinated case law in federal court. It serves as a reminder that counsel bears the ultimate responsibility for verifying the existence and accuracy of all cited authorities, regardless of the research tools employed.
Why this matter is tracked
In a breach of contract and insurance bad faith action, the N.D. California court granted the defendant's motion to dismiss with prejudice. During the proceedings, the court identified that plaintiff's counsel cited a non-existent case, 'Moss v. Provident Life and Accident Insurance Company, 2009 WL 4043065 (S.D. Cal. 2009).' The court noted that the cited case does not exist and that the language attributed to it was also fabricated. The court expressed concern that counsel relied on an artificial intelligence tool to generate the nonexistent citation and issued a formal warning that future submissions of nonexistent authority may result in appropriate sanctions.
This case highlights the judicial response to the submission of AI-hallucinated case law in federal court. It serves as a reminder that counsel bears the ultimate responsibility for verifying the existence and accuracy of all cited authorities, regardless of the research tools employed.
Record details
What the record establishes about AI use
The court noted counsel likely relied on an artificial intelligence tool.
Order granting defendant's motion to dismiss the second amended complaint with prejudice.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Plaintiff's counsel cited a non-existent case 'Moss v. Provident Life and Accident Insurance Company, 2009 WL 4043065 (S.D. Cal. 2009)'; the Court found the citation does not exist and noted counsel likely relied on an AI tool.
Questions this record answers
- What happened in Zhdanovich-Doty v. Provident Life and Accident Insurance Company?
- The court issued a warning to plaintiff's counsel after identifying that counsel submitted a fabricated case citation, likely generated by an artificial intelligence tool. The court explicitly cautioned that any future submission of nonexistent authority may result in further sanctions.
- Why does Zhdanovich-Doty v. Provident Life and Accident Insurance Company matter for legal AI risk?
- This case highlights the judicial response to the submission of AI-hallucinated case law in federal court. It serves as a reminder that counsel bears the ultimate responsibility for verifying the existence and accuracy of all cited authorities, regardless of the research tools employed.
- What does the public record establish about Zhdanovich-Doty v. Provident Life and Accident Insurance Company?
- 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 Zhdanovich-Doty v. Provident Life and Accident Insurance Company 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.