Sanction teardown · Los Angeles SC, California, USA · 2026-08-11
Fa’alagilagi Meni-Siliga v. A’s Contractor, Inc., et al.
What happened
In Los Angeles SC, California, USA, a filing relied on Irys to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Case Law)Cited in State Farm's MIL No. 1; later admitted by counsel to be a non-existent, AI-generated case citation.
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Fabricated (Case Law)Cited in State Farm's MIL No. 1; identified as a non-existent citation after investigation.
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Fabricated (Case Law)Cited in State Farm's MIL No. 1; admitted by counsel to be fabricated.
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Fabricated (Case Law)Cited in State Farm's MIL No. 1; identified as a non-existent citation in counsel's review.
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Fabricated (Case Law)Cited in State Farm's MIL No. 3; found by counsel to be a non-existent AI-generated citation.
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Fabricated (Case Law)Cited in State Farm's MIL No. 3; admitted by counsel to be non-existent after verification.
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Fabricated (Case Law)Cited in State Farm's MIL No. 5; counsel's investigation determined the citation did not exist.
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False Quotes (Case Law)State Farm attributed two direct quotations to Rattan that are not direct quotes from that decision; counsel notes Rattan's actual holding about regulations not creating a private right of action.
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Misrepresented (Case Law)The memorandum misstated the case title of Wesson v. Staples twice; counsel clarifies Wesson exists but the title was mis-stated in the brief.
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False Quotes (Case Law)Two quotations were erroneously attributed as direct quotes to Nickerson though the declaration notes the Nickerson text does not contain those exact quoted passages.
Which AI tool
Irys. 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
Not specified in source record.
Additional detail
Defense counsel (State Farm) admitted that use of the AI tool Irys produced multiple non-existent case citations across its motions in limine and that some quotations were not attributable to the cited authorities. Opposing counsel discovered the issues, informed the court, and defense counsel investigated, identified seven fabricated case citations and several misattributed/false quotes, apologized, and filed redlined corrections. No sanctions or penalties are recorded in the declaration.
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.
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Source: https://www.damiencharlotin.com/documents/2847/Jacqueline_Robinson_decl_re_Irys.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).