Was Flowz Digital v. Caroline Dalal sanctioned over AI-generated citations?

Flowz Digital v. Caroline Dalal (C.D. Cal, May 30, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary penalty: $3,500 on plaintiff's counsel (Omid Khalifeh), payable to the Clerk; counsel also directed to notify the California State Bar.. $3,500 in monetary penalties.

Which AI tool was involved in Flowz Digital v. Caroline Dalal?

The order in Flowz Digital v. Caroline Dalal does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

May 30, 2025 · AI sanctions database

Flowz Digital v. Caroline Dalal

Flowz Digital v. Caroline Dalal is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: C.D. Cal
Date: May 30, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary penalty: $3,500 on plaintiff's counsel (Omid Khalifeh), payable to the Clerk; counsel also directed to notify the California State Bar.
Penalty: $3,500 in monetary penalties.

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What the record shows

Following an order to show cause, the court sanctioned plaintiff's counsel $3,500 under Rule 11 after an opposition brief cited a case (Shell Petroleum) the court found did not exist and that counsel acknowledged had been generated by Lexis+ AI. Counsel was ordered to pay the sanction to the Clerk and to notify the California State Bar of the sanction.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · C.D. Cal

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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