Which AI tool was involved in Gregoire v. Board of Trustees of SF BART?

The order in Gregoire v. Board of Trustees of SF BART 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 6, 2026 · AI sanctions database

Gregoire v. Board of Trustees of SF BART

Gregoire v. Board of Trustees of SF BART 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: N.D. California
Date: May 6, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary penalty: $1,000; serve order on client; CLE; State Bar notified
Penalty: $1,000 in monetary penalties.

FineProfessional sanctionBar referral

What the record shows

The court found that three of four cases cited in plaintiff's opposition could not be located, which it found suggested hallucinations from generative AI tools, and stated that citing nonexistent case law amounts to an inaccurate statement to the court. The court personally sanctioned counsel Jessica Barsotti $1,000 payable to the Clerk, required her to serve the order on her client and complete CLE on ethical AI use, and directed the Clerk to serve the order on the State Bar of California.

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 ↗

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 · N.D. California

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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