Tekoma Chaney v. Transdev Services Inc.
The case
Tekoma Chaney v. Transdev Services Inc., C.D. California, No. 2:24-cv-10761-ODW-AJR, Document 46, order filed April 28, 2026. Copy of primary document: `files/sources/D-140-chaney-v-transdev.pdf`. Source URL: https://www.damiencharlotin.com/documents/2041/Chaney_v._Transdev_Services_USA_28_April_2026.pdf
What happened
Counsel Gavril T. Gabriel admitted using LexisNexis+ and its drafting feature Protégé to draft portions of his briefs. The fake case "In re Shubert" appeared three times across two summary judgment oppositions. Gabriel buried his admission in a declaration that mostly attacked the defendants' replies, initially framed the fake citation as a copy-and-paste error, and never disclosed that the same fabricated case appeared twice more in a separate brief. The court found he repeatedly attempted to hide and minimize his generative-AI misuse.
The rule and the sanction
Sanctions under the court's inherent authority, with a specific finding of bad faith. The court imposed $2,500 in sanctions payable to the Court by May 28, 2026, and ordered Gabriel to file a declaration in every Central District case in which he appears, explaining how he used generative AI in this case and detailing the court's bad faith findings, and to email that declaration to the chambers of every Central District judge before whom he does not appear, all by May 12, 2026. Noncompliance risks contempt proceedings and referral to the California State Bar.
How it could have been avoided
Disclose AI use forthrightly the first time the court asks, because burying an admission becomes a separate bad-faith finding. Check every brief for hallucinated citations, not just the one the other side flagged. Expect mandatory disclosures to every judge in the district when a court finds deliberate obfuscation.