Yasiel Puig Valdes v. All3 Media, LLC

Yasiel Puig Valdes v. All3 Media, LLC, et al., No. 25STCV15503, Superior Court of California, County of Los Angeles, ruling on special motion to strike (anti-SLAPP) filed October 15, 2025. The order is reproduced in the Reason/Volokh article by Eugene Volokh dated October 27, 2025. Copy of primary document: `files/sources/D-96-puig-valdes-v-all3media.pdf`.

Plaintiff's counsel (unnamed in the order) cited two nonexistent cases, "Edwards v. Hearst Corp. (1991) 53 Cal.3d 30, 43" and "Heath v. San Joaquin Comm. Hosp. Dist. (1993) 15 Cal.App.4th 708, 713-14," in his opposition to the anti-SLAPP motion. At the hearing, counsel confirmed the citations do not exist and had appeared when he sought ChatGPT's assistance in filing the opposition. He then filed an ex parte application "to correct" the errors, which the court denied along with the request to strike the opposition.

The court stated it is "keenly aware that relying on fabricated legal authority is sanctionable," but concluded the State Bar was better equipped to investigate, and therefore referred the conduct to the Chief Trial Counsel of the State Bar of California. A referral to the bar for AI misconduct is a Tier 1 consequence under the library's inclusion rule.

Verify every citation against an official reporter or full-text database before filing an opposition. Never present ChatGPT output as authority without confirming the cases exist and say what they are cited for. If errors are discovered, correct them candidly and promptly rather than through an ex parte patch.