Buchanan v. Vuori, Inc.
The case
Buchanan v. Vuori, Inc., No. 5:23-cv-01121-NC (N.D. Cal.), sanctions order (Document 96) filed November 20, 2025. Federal district court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-110-buchanan-v-vuori.pdf`.
What happened
Attorney James Dal Bon used approximately six different AI tools, having them cross-check each other, and filed briefing containing one nonexistent case and eight fabricated quotations. He admitted the AI use led to hallucinated authority. The court also found him inadequate as class counsel.
The rule and the sanction
Rule 11, Federal Rules of Civil Procedure, and the court's inherent authority. Sanctions: ECF 81 and 89 stricken without leave to refile; $250 payable to the Clerk by December 5, 2025; and referral to the Standing Committee on Professional Conduct (the court had already ordered client notice).
How it could have been avoided
(a) AI tools cross-checking each other still fail on real legal authority; only a human checking a primary database counts as verification. (b) More tools do not equal more diligence; one careful review beats six automated ones. (c) In class actions, AI errors also jeopardize adequacy of counsel findings, raising the stakes.
---