Oneto v. Watson

Roy J. Oneto v. Melvin Watson, et al., N.D. Cal., Order Sanctioning Plaintiff's Counsel, Edward A. Quesada, filed October 10, 2025. Copy of primary document: `files/sources/D-94-oneto-v-watson.pdf`.

Attorney Edward A. Quesada, counsel for plaintiff, filed briefs containing fictitious case citations. He declared that he did not knowingly use AI, but his explanation was that he had copied and pasted material from Google's AI Overview into his briefing without recognizing it as AI-generated content, and he never verified the citations.

The court found violations of Federal Rule of Civil Procedure 11(b), counsel's ethical duties, and the court's standing order on AI. Sanctions: a $1,000 monetary sanction against Quesada personally, payable to the Clerk of Court; service of the order on his client; completion of a continuing legal education course of at least one hour on the ethical use of artificial intelligence in the practice of law; and a directive to the Clerk of the Court to serve the order on the State Bar of California.

Treat any material copied from a search engine's AI summary as unverified AI output, even if the lawyer did not deliberately "use AI." Verify every citation against the cited authority before filing. Disclose AI assistance per court standing orders and complete AI ethics training before relying on such tools.