Jaime Arguello Amaya Quinteros v. Harbor Distributing, LLC, et al.

Summary

The California Court of Appeal affirmed monetary and related sanctions imposed on a law firm and its attorneys under Code of Civil Procedure section 128.7. The sanctions arose from a meritless opposition to a motion to stay that contained inaccurate citations, fabricated quotations, and misrepresentations of legal authority, apparently involving generative artificial intelligence. The court held that the appellants forfeited their challenges based on section 128.7’s safe-harbor provision and that the sanctions were not an abuse of discretion.

Holdings

1. LLG forfeited its claims that the trial court violated section 128.7, subdivision (c)(2), because it did not raise or object to the alleged safe-harbor defects in the trial court.
2. The trial court did not abuse its discretion in imposing sanctions against LLG and the attorneys of record for filing a groundless opposition containing fabricated quotations, inaccurate citations, and misrepresentations of authority.
3. LLG forfeited its challenge to the award of $5,000 payable to Harbor by failing to raise the issue in the trial court and inadequately presenting it on appeal.

Questions Presented

1. Whether LLG forfeited its claims that the trial court violated the 21-day safe-harbor requirements of Code of Civil Procedure section 128.7, subdivision (c)(2).
2. Whether the trial court abused its discretion by imposing sanctions for LLG's filing of an opposition containing fabricated quotations, inaccurate citations, and misrepresentations of legal authority.
3. Whether LLG forfeited its challenge to the portion of the sanctions payable to Harbor.

Disposition

affirmed