Replays · Cal. Ct. App. · September 12, 2025
An appeal from summary judgment on employment claims. The court affirmed, and its published opinion turned to the briefs: by the court's count, 21 of the 23 case quotations in the opening brief were not real quotations. It gave a few examples.
"That is, the quotes plaintiff attributes to published cases do not appear in those cases or anywhere else." (Opinion (certified for publication), p. 2)
"Had he read them, he would have discovered, as we did, that the cases did not contain the language he purported to quote, did not support the propositions for which they were cited, or did not exist." (Opinion (certified for publication), p. 25)
| as filed | what the court said | what the register holds at this citation | our default check today | |
|---|---|---|---|---|
| 1 | Schimmel v. Levin (2011) 195 Cal.App.4th 81, 86-87Quoted in the filing: "Section 437c(f)(2) embodies a legislative judgment that a party should not be allowed to bring multiple motions for summary judgment based on the same issues without demonstrating newly discovered facts or circumstances or a change in the law." | The quoted language does not appear in Schimmel, or in any other case of which the court is aware; Schimmel also "does not contain a single reference to either summary judgment or section 437c." (p. 9) | Schimmel v. Levin (Cal. Ct. App. 2011) | Check this Quoted language not in the opinion |
| 2 | Regency Health Services, Inc. v. Superior Court (1998) 64 Cal.App.4th 1496, 1504Quoted in the filing: "A continuance should not be granted when it is sought to facilitate procedural maneuvers rather than to promote justice." | "Regency does not address the granting of a continuance, and the quoted language does not appear anywhere in the opinion." (p. 9) | REGENCY HEALTH SERVICES v. Superior Court (Cal. Ct. App. 1998) | Check this Quoted language not in the opinion |
| 3 | Peake v. Underwood, 227 Cal.App.4th 428, 448 (2014) | "Peake does not address the filing of a second dispositive motion, and the only sanctions at issue in that case were for filing a frivolous pleading." (p. 10) | Peake v. Underwood (Cal. Ct. App. 2014) | Found Found: Peake v. Underwood (Cal. Ct. App. 2014) |
| 4 | Goldstine v. Liberty Mut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020) | The court wrote that Goldstine appears not to be a real case. (p. 10) | A Westlaw number, not a page. No open register holds these. | Cannot verify Westlaw/Lexis identifier. Open registers cannot resolve it |
| 5 | Heckert v. MacDonald, 208 Cal.App.3d 832, 837 (1989)Quoted in the filing: "frivolous litigation tactics" | "The words 'frivolous,' 'unfair,' and 'tactics' do not appear in Heckert, which concerns the appellants' claim that the trial court erred by refusing to order their real estate broker to pay their attorney fees as damages." (p. 10) | Heckert v. MacDonald (Cal. Ct. App. 1989) | Found Found: Heckert v. MacDonald (Cal. Ct. App. 1989)The quotation is too short to check (fewer than five content words).The brief quotes three words ("frivolous litigation tactics"), too few for the quote check, so the row reports the case only. |
5 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 2 Check this, 1 Cannot verify, 2 Found. Each citation was pasted as a line of text (the quoted words first, where we have them) and checked the way the checker checks a draft: no language model, nothing stored. The register column is a direct lookup of the volume and page.
Two red rows (the check could not find the Schimmel and Regency quotations in those opinions) and one Westlaw number to look up. The Peake and Heckert rows would have come back Found: the default check does not read what a case holds, and the Heckert quotation is too short to check.
Paste the draft or upload the PDF. The default check reads every case citation and returns rows like the ones above in a few seconds, with no language model and nothing stored. It is free to try without an account. Then read what the court would read: every case you cite, at the page you cite.
Check a draft before you fileAll replays
Published September 24, 2026, updated September 24, 2026. We read the decision and copied the court's list; if we have misread it, write to hello@proofread.law. The rows are from the run dated above; they can change when the checker does.