What was hallucinated

Misrepresented: Case Law | Appellant cited Southern Cal. Gas Co. v. Public Utilities Com. as holding courts must evaluate standing based on objective evidence; the court noted that Southern Cal. Gas does not discuss standing and thus was misapplied. || Misrepresented: Case Law | Appellant relied on Patterson v. Superior Court for the proposition that courts cannot presume standing; the court observed Patterson does not address standing and that Patterson was disapproved by Ramirez. || Fabricated: Legal Norm | In her reply brief appellant cited a nonexistent 'Code of Civil Procedure section 2330' claiming it mandates how agency relationships must be established; the court treated this statute as a nonexistent citation. || Misrepresented: Legal Norm | Appellant misquoted Code of Civil Procedure section 437c, subdivision (f)(2), claiming it bars granting summary judgment while a counter-motion is pending; the court noted the subdivision's actual text differs from appellant's description. || False Quotes: Case Law | Appellant attributed the sentence 'Standing is a jurisdictional issue that must be addressed before the merits of a case may be reached.' to Apartment Assn. of Los Angeles County, Inc. v. City of Los Angeles; the court found the quoted language does not appear in that opinion. || False Quotes: Case Law | Appellant quoted Angelucci v. Century Supper Club as stating 'A plaintiff must have a real, present interest in the outcome – not just a theoretical or governmental interest in enforcing its laws.' The court found the quote is not in Angelucci.

Sanction teardown · CA California, USA · 2025-12-01

Kingdom of Sweden v. Samantha Ashhadi Soliman

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:

Misrepresented (Case Law)

Appellant cited Southern Cal. Gas Co. v. Public Utilities Com. as holding courts must evaluate standing based on objective evidence; the court noted that Southern Cal. Gas does not discuss standing and thus was misapplied.
Misrepresented (Case Law)

Appellant relied on Patterson v. Superior Court for the proposition that courts cannot presume standing; the court observed Patterson does not address standing and that Patterson was disapproved by Ramirez.
Fabricated (Legal Norm)

In her reply brief appellant cited a nonexistent 'Code of Civil Procedure section 2330' claiming it mandates how agency relationships must be established; the court treated this statute as a nonexistent citation.
Misrepresented (Legal Norm)

Appellant misquoted Code of Civil Procedure section 437c, subdivision (f)(2), claiming it bars granting summary judgment while a counter-motion is pending; the court noted the subdivision's actual text differs from appellant's description.
False Quotes (Case Law)

Appellant attributed the sentence 'Standing is a jurisdictional issue that must be addressed before the merits of a case may be reached.' to Apartment Assn. of Los Angeles County, Inc. v. City of Los Angeles; the court found the quoted language does not appear in that opinion.
False Quotes (Case Law)

Appellant quoted Angelucci v. Century Supper Club as stating 'A plaintiff must have a real, present interest in the outcome – not just a theoretical or governmental interest in enforcing its laws.' The court found the quote is not in Angelucci.

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

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/1114/Sweden_v._Ashhadi_USA_1_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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