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Technology,
Ethics/Professional Responsibility,
Civil Procedure

Mar. 13, 2026

Citation Laundering: How fake cases gain legitimacy by passing through real legal documents

A dog custody dispute, a blogger named Sassafras Patterdale, and $5,000 in sanctions. A lesson about fabricated citations that applies to every courtroom in California.

James Mixon

Managing Attorney
California Court of Appeal, Second Appellate District

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Citation Laundering: How fake cases gain legitimacy by passing through real legal documents

I was deep in the outline for an ethics seminar, the kind where you want crisp hypotheticals and maybe a touch of drama, when a colleague forwarded me a published opinion from the Fourth District. "You're going to want to read this," she wrote. No further context.

She was right.

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