Schlichter v. Kennedy
The case
Schlichter v. Kennedy, No. E083744 (Cal. Ct. App., 4th Dist., Div. 2), sanctions order filed November 17, 2025. State intermediate appellate court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-109-schlichter-v-kennedy.pdf`.
What happened
Attorney Jeffrey Dean Grotke admitted using AI to regenerate the appellant's opening brief (and possibly the writ), resulting in four spurious citations. He attributed the errors to clerical mistakes, but the court found that explanation not credible and concluded the citations bore the hallmarks of AI hallucinations.
The rule and the sanction
Violation of the court's rules on accurate briefing (unreasonable violation). Sanction: $1,750 payable to the court, imposed on Grotke individually, with the clerk directed to notify the State Bar of California.
How it could have been avoided
(a) "Clerical error" does not explain fabricated citations; admitting the AI source and showing corrective steps goes further. (b) Personally re-verify every citation after any AI regeneration of a brief. (c) Keep AI use out of the final drafting pass or disclose it with a verification log.
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