Gregoire v. Board of Trustees of SF BART
The case
Gregoire v. Board of Trustees of SF BART, N.D. Cal., No. 25-cv-02150-TSH, order filed May 6, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-148-gregoire-v-bart.pdf`.
What happened
Attorney Jessica Barsotti filed papers containing fictitious citations the court was concerned suggested AI hallucinations; the court made no finding on their origin, and she then failed to respond to the court's order to show cause.
The rule and the sanction
Rule 11 and the duty of candor. Sanctions: a $1,000 fine; notice to the client; one hour of AI continuing legal education; and service of the order on the California State Bar. Subsequent history (outside the graded set): a third order to show cause (ECF 44, May 6, 2026) issued over inaccuracies in Barsotti's ECF 40-1 declaration; Doc. 46 (May 12, 2026) extended a deadline with a $50/day warning; and Doc. 56 (June 12, 2026) discharged the third OSC after her response at ECF 53, with $50/day sanctions running from June 9, 2026 until the response was filed. (per the Justia docket, located at Stage 2; documents not held)
How it could have been avoided
Verify every citation before filing, and never ignore an order to show cause. A non-response removes any chance to present mitigation and effectively concedes the sanction.
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