What was hallucinated

Fabricated: Case Law | Court could not locate the cited decision and suspects this cited authority may be an AI-fabricated case; flagged as potentially fabricated citation. || False Quotes: Case Law | Plaintiff attributed a quotation to Henrichs that does not appear in the opinion; court found the quoted language absent from the decision. || False Quotes: Case Law | Plaintiff claimed Kougasian contained a specific phrasing ('gravamen') that the opinion does not contain; court identified the quotation as inaccurate. || False Quotes: Case Law | Plaintiff quoted Leadsinger for a proposition about continuing violations using wording that does not appear in the opinion; court noted the quoted terms are absent.

Sanction teardown · D. Guam, USA · 2025-12-03

Eddie Lawrence Quitugua v. Donna P. Quitugua, et al.

What happened

In D. Guam, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Court could not locate the cited decision and suspects this cited authority may be an AI-fabricated case; flagged as potentially fabricated citation.
False Quotes (Case Law)

Plaintiff attributed a quotation to Henrichs that does not appear in the opinion; court found the quoted language absent from the decision.
False Quotes (Case Law)

Plaintiff claimed Kougasian contained a specific phrasing ('gravamen') that the opinion does not contain; court identified the quotation as inaccurate.
False Quotes (Case Law)

Plaintiff quoted Leadsinger for a proposition about continuing violations using wording that does not appear in the opinion; court noted the quoted terms are absent.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Warning

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1149/Quitugua_v._Quitugua_USA_3_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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