People v. Alvarez (D084581)

People v. Alvarez, No. D084581 (Cal. Ct. App., 4th Dist., Div. 1), sanctions order filed October 2, 2025, imposing a $1,500 sanction on attorney LeRoy George Siddell. Primary order: https://www.courts.ca.gov/opinions/archive/D084581.PDF (correction: an earlier version of this entry linked a Justia opinion for an unrelated case, Schlichter v. Kennedy).

In People v. Alvarez, defense counsel LeRoy George Siddell, opposing a motion to dismiss the appeal, cited one nonexistent case, fabricated a quotation attributed to In re Benoit (1973) 10 Cal.3d 72, 87–88, and misrepresented the legal propositions of two other cases. He admitted to the court his "lack of professionalism" for "failing to verify cases provided to [him] by artificial intelligence."

The court found the conduct "unprofessional" and imposed a $1,500 sanction, citing Code of Civil Procedure § 128.7(b)(2) as a "see, e.g." deterrence reference and agreeing with Noland that "attorneys must check every citation to make sure the case exists and the citations are correct." Before the order issued, the court accepted his motion to withdraw as counsel, after confirming he had informed his client, and new counsel was appointed.

Criminal matters carry the same verification duty as civil ones. Read each cited case before citing it; confirm the cited pages actually state the proposition. If AI supplied the research, re-run the research in a verified legal database and discard anything you cannot confirm.

• Primary order: https://www.courts.ca.gov/opinions/archive/D084581.PDF