Zhdanovich-Doty v. Provident Life and Accident Insurance Company
N.D. California · Jun 22, 2026
- Jurisdiction
- federal
- Court
- N.D. California
- Record ID
- zhdanovich-doty-v-provident-life-and-accident-insurance-company-2026-06-22
- Observed outcome
- The court granted the defendant's motion to dismiss with prejudice and issued a formal warning to plaintiff's counsel regarding the use of AI-generated fabricated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fake Citations
- Contract
- Trial
- Warning
- AI attribution
- Reported
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- Order granting defendant's motion to dismiss the second amended complaint with prejudice.
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
The court noted counsel likely relied on an artificial intelligence tool.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.