AI tool not identified in the record. A clean-looking Second Circuit cite that points to nothing.
Ashley Gjovik, a former Apple employee proceeding pro se, sued Apple in the Northern District of California over her termination. The order resolved her motion to strike Apple's affirmative defenses and her motion for a more definite statement. In its briefing, Apple raised Gjovik's use of artificial intelligence and asked for Rule 11 sanctions.
Gjovik admitted she used AI. Apple pointed to a number of examples where the AI-generated or AI-provided information she filed was not correct, which the court read as a sign she had not verified it. Gjovik said she was exercising oversight and making a good faith effort to review and edit the content, but she did not address the specific examples Apple identified.
Offered for: that prosecutorial immunity falls away when charges are knowingly false
The court granted the motion to strike in part and denied it in part, and denied the motion for a more definite statement. It declined to impose sanctions at this stage. It forewarned Gjovik that she is responsible for verifying the accuracy of AI-generated information, including case citations, and that failure to do so may lead to sanctions, a contempt finding, or loss of the ability to proceed pro se.
Kingsfield returned REJECT. The reporter location resolves to no decision by this name. The cite is fabricated.
This matter is among the US case-law cases we ran Kingsfield against in the Charlotin benchmark. Kingsfield's existence check confirms every citation against the case-law corpus and an independent source (CourtListener) before any claim resting on it can stand. Across the run Kingsfield ruled 696 of 700 testable claims correctly, including every one of the 504 fabricated citations and 92 fabricated quotes.
Honest scope. This measures Kingsfield's ruling layer given an extracted citation, not an end-to-end run over a full brief. The case record and the AI-tool attribution come from Damien Charlotin's public database and the court order; the verdict is Kingsfield's. See the full 700-claim benchmark.