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Hocog v. Cook-Huynh

Court
Superior Court of Guam
Jurisdiction
USA
Decided
2025-08-11
AI tool
implied
Outcome
Pending
Monetary penalty
None reported

What was hallucinated

Fabricated: Legal Norm | Plaintiffs cited 7 GCA §10105, which does not exist (likely intended 10 GCA §10105). || Fabricated: Legal Norm | Plaintiffs cited 7 GCA §11038(3), which does not exist. || False Quotes: Case Law | Provided quotations attributed to Brown v. Dillard IV, Inc. (430 F.3d 1004 (9th Cir. 2005)) that the court found do not appear in the opinion. || False Quotes: Case Law | Quoted language purportedly from Westcon Construction Corp. v. County of Sacramento (152 Cal. App. 4th 183 (2007)) that the court could not locate in that opinion. || Outdated Advice: Overturned Case Law | Cited Diaz v. Bukey (195 Cal. App. 4th 315 (2001)) for a proposition without noting the opinion was later vacated by the California Supreme Court; the brief also included an unrelated citation (262 P.3d 1007). || Misrepresented: Case Law | Cited Penthouse Int'l, Ltd. v. Playboy Enters., Inc. (663 F.2d 371 (2d Cir. 1981)) for an estoppel/apparent authority principle that the court found is not discussed in that opinion. || Misrepresented: Case Law | Referenced 'In re Application of Santos, 2001 Guam 1' but the court explained 2001 Guam 1 is a different criminal case (People v. Chargualaf), indicating a misidentification/mischaracterization. || Misrepresented: Case Law | Cited 'Lin SHR Construction Co. v. Acetown, Inc., 2023 Guam 18' as a Guam Supreme Court authority though it is a Superior Court matter and 2023 Guam 18 corresponds to an unrelated criminal citation (People v. Aidan).

Sanction teardown · Superior Court of Guam, USA · 2025-08-11

Hocog v. Cook-Huynh

What happened

In Superior Court of 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 (Legal Norm)
    Plaintiffs cited 7 GCA §10105, which does not exist (likely intended 10 GCA §10105).
  • Fabricated (Legal Norm)
    Plaintiffs cited 7 GCA §11038(3), which does not exist.
  • False Quotes (Case Law)
    Provided quotations attributed to Brown v. Dillard IV, Inc. (430 F.3d 1004 (9th Cir. 2005)) that the court found do not appear in the opinion.
  • False Quotes (Case Law)
    Quoted language purportedly from Westcon Construction Corp. v. County of Sacramento (152 Cal. App. 4th 183 (2007)) that the court could not locate in that opinion.
  • Outdated Advice (Overturned Case Law)
    Cited Diaz v. Bukey (195 Cal. App. 4th 315 (2001)) for a proposition without noting the opinion was later vacated by the California Supreme Court; the brief also included an unrelated citation (262 P.3d 1007).
  • Misrepresented (Case Law)
    Cited Penthouse Int'l, Ltd. v. Playboy Enters., Inc. (663 F.2d 371 (2d Cir. 1981)) for an estoppel/apparent authority principle that the court found is not discussed in that opinion.
  • Misrepresented (Case Law)
    Referenced 'In re Application of Santos, 2001 Guam 1' but the court explained 2001 Guam 1 is a different criminal case (People v. Chargualaf), indicating a misidentification/mischaracterization.
  • Misrepresented (Case Law)
    Cited 'Lin SHR Construction Co. v. Acetown, Inc., 2023 Guam 18' as a Guam Supreme Court authority though it is a Superior Court matter and 2023 Guam 18 corresponds to an unrelated criminal citation (People v. Aidan).

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

Pending

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/724/Decision_and_Order_Granting_Defendant_Dr._Mariana_Cook-Huynhs_Motion_To_Dismiss.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/724/Decision_and_Order_Granting_Defendant_Dr._Mariana_Cook-Huynhs_Motion_To_Dismiss.pdf

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