What was hallucinated

Fabricated: Case Law | Plaintiff's counsel cited a nonexistent case 'Morgan v. State of California, 157 Cal. App. 4th 914, 922 (2007)'; the Court found no case of that name and noted the intended citation was Chamberlain v. Cocola Assocs., 958 F.2d 282 (9th Cir. 1992). || Fabricated: Case Law | Counsel for CDC cited a nonexistent authority 'Humphries v. Rice, 88 Cal. App. 4th 1413, 1424 (2001)'; the Court found the citation incorrect and noted counsel intended to cite Eddy v. Sharp, 199 Cal. App. 3d 858 (1988). || Misrepresented: Legal Norm | Plaintiff's counsel misquoted Cal. Civ. Code § 988(c), attributing language to the statute that it does not contain; the Court admonished counsel for the misquotation.

Details

The Court identified multiple instances where counsel cited nonexistent cases and misquoted Cal. Civ. Code § 988(c). The Court admonished counsel, noted corrections in later briefing, and declined to credit the arguments based on the erroneous citations. No sanctions were imposed.

Sanction teardown · N.D. California, USA · 2025-11-07

Marc Henri David v. George Chiala Farms, Inc.

What happened

In N.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:

Fabricated (Case Law)

Plaintiff's counsel cited a nonexistent case 'Morgan v. State of California, 157 Cal. App. 4th 914, 922 (2007)'; the Court found no case of that name and noted the intended citation was Chamberlain v. Cocola Assocs., 958 F.2d 282 (9th Cir. 1992).
Fabricated (Case Law)

Counsel for CDC cited a nonexistent authority 'Humphries v. Rice, 88 Cal. App. 4th 1413, 1424 (2001)'; the Court found the citation incorrect and noted counsel intended to cite Eddy v. Sharp, 199 Cal. App. 3d 858 (1988).
Misrepresented (Legal Norm)

Plaintiff's counsel misquoted Cal. Civ. Code § 988(c), attributing language to the statute that it does not contain; the Court admonished counsel for the misquotation.

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

Additional detail

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/992/David_v._George_Chiala_Farms_USA_7_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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