What was hallucinated

Misrepresented: Case Law | Plaintiff relied on Pierce v. Cnty. of Orange, 526 F.3d 1190 (9th Cir. 2008) for a statute-of-limitations/continuing-violation proposition; court noted the cited opinion exists but does not discuss the statute-of-limitations or continuing-violation issues relied upon, i.e., a mischaracterization of precedent. || Fabricated: Case Law | Plaintiff cited Boling v. Pub. Utils. Comm'n, 105 Cal.App.3d 805 (1980); court found this case does not exist and flagged it as a fabricated citation. || Fabricated: Case Law | Plaintiff cited Loving v. Cnty. of Stanislaus, 33 Cal.App.5th 444 (2019); court found this case does not exist and treated it as fabricated.

Sanction teardown · E.D. California, USA · 2026-07-24

Kimberly A. Graves v. Pacific Gas and Electric Company

What happened

In E.D. 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:

Misrepresented (Case Law)

Plaintiff relied on Pierce v. Cnty. of Orange, 526 F.3d 1190 (9th Cir. 2008) for a statute-of-limitations/continuing-violation proposition; court noted the cited opinion exists but does not discuss the statute-of-limitations or continuing-violation issues relied upon, i.e., a mischaracterization of precedent.
Fabricated (Case Law)

Plaintiff cited Boling v. Pub. Utils. Comm'n, 105 Cal.App.3d 805 (1980); court found this case does not exist and flagged it as a fabricated citation.
Fabricated (Case Law)

Plaintiff cited Loving v. Cnty. of Stanislaus, 33 Cal.App.5th 444 (2019); court found this case does not exist and treated it as fabricated.

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

Admonishment & 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.

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Source: https://www.damiencharlotin.com/documents/2704/Graves_v._PGE_USA_24_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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