Allen v. Mercedes-Benz USA LLC, 2:25-cv-01222

Plaintiff Juan Eric Allen, represented by attorney Erik Whitman, filed suit against Mercedes-Benz USA LLC in California state court.
The case was removed to federal court by Mercedes-Benz.
Allen, through Whitman, moved to remand the case back to state court.
In his reply supporting remand, Whitman cited quotations supposedly from case law which the court could not verify as authentic.
The court ordered Whitman to explain the origins of these quotations; his response was late and included further unsupported quotations.
The court reviewed the filings and found multiple instances of fabricated quotations presented as legal authority by Whitman.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Alleged Misrepresentation	Whitman argued his cited quotations accurately represented Ninth Circuit law on removability.	Not specifically detailed.	Court found the quotations were fabricated and not supported by cited authorities.
Rule 11 Violation	Whitman claimed his filings reflected existing law or reasonable legal argument.	Not specifically detailed.	Court found violation: Whitman did not conduct reasonable inquiry and filed false content.
Local Rule 180(e) Violation	No admission; argued adherence to legal standards.	Not specifically detailed.	Court found violation of professional conduct by knowingly making false legal statements.
Referral for Discipline	Whitman did not address potential disciplinary consequences.	Not specifically detailed.	Referred Whitman to the State Bar of California for appropriate disciplinary action.

Crum v. Circus Circus Enterprises, 231 F.3d 1129 (9th Cir. 2000) (addressed legal certainty standard for jurisdictional amount, not removal procedures or post-removal evidence)
Matheson v. Progressive Specialty Ins. Co., 319 F.3d 1089 (9th Cir. 2003) (discussed sufficiency of allegations to establish amount in controversy, not post-removal evidence)