Was That Xiong v. Minga Wofford (1) sanctioned over AI-generated citations?

That Xiong v. Minga Wofford (1) (E.D. California, January 22, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Remedial order: counsel and staff to read hearing transcript. No monetary penalty in this order.

Which AI tool was involved in That Xiong v. Minga Wofford (1)?

The order in That Xiong v. Minga Wofford (1) does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

January 22, 2026 · AI sanctions database

That Xiong v. Minga Wofford (1)

That Xiong v. Minga Wofford (1) 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: E.D. California
Date: January 22, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Remedial order: counsel and staff to read hearing transcript
Penalty: No monetary penalty in this order.

What the record shows

The court identified two cases in petitioner's reply, 'Phan v. Barr' and 'Flores v. Barr', that appeared to be hallucinations. After addressing the hallucinated citations at a hearing, the court ordered petitioner's counsel to obtain the hearing transcript, provide it to the law student and staff who worked on the filings, require them to read it, and provide written confirmation of completion.

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 · E.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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