Sanction teardown · CA California, USA · 2025-12-18
JPMorgan Chase Bank, N.A. v. Christina Buenzli
What happened
In CA California, 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:
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Fabricated (Case Law)Appellant cited a non-existent case and attributed a quotation to it; court found the case/citation does not exist.
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Fabricated (Case Law)Appellant cited a non-existent Unifund decision and attributed a quoted formulation; court found citation incorrect/nonexistent.
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Fabricated (Case Law)Appellant cited a Westlaw citation she attributed a quote to; court found the cited decision/citation does not match and quote not found.
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False Quotes (Case Law)Appellant cited an existing case but attributed a quotation that does not appear in that opinion; court found the quote unsupported by the cited authority.
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False Quotes (Case Law)Appellant cited an existing opinion but attributed a specific evidentiary requirement/quote not found in the opinion; court flagged misattribution.
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False Quotes (Case Law)Appellant cited an existing case name/year but attributed a quote and holding not present in the opinion; court found the quote absent from reported sources.
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Fabricated (Case Law)Appellant cited a non-existent supplemental reporter decision and attributed a doctrinal quote; court found citation nonexistent.
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Fabricated (Case Law)Appellant cited a purported California Supreme Court decision that does not exist at that citation; court found the citation incorrect/nonexistent.
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Fabricated (Case Law)Appellant cited a purported supplemental appellate decision with a quoted proposition about debt buyers; court found the cited authority does not exist or is mis-cited.
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
Not specified in source record.
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/1196/Jp_Morgan_v._Buenzli_USA_18_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).