What was hallucinated

False Quotes: Case Law | Two purported direct quotations attributed to Ninth Circuit cases (identified by counsel as Saman and Mitchell) in Plaintiff's response to defendant's fee motion (Doc.155) do not appear in those cases; counsel admitted she neglected to remove quotation marks. || False Quotes: Case Law | Purported quotation attributed to United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001) in Plaintiff's 'Brief on Impeachment' (Doc.124) does not appear in Antonakeas. || False Quotes: Case Law | Purported quotation attributed to United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009) in the same brief (Doc.124) does not appear in Osazuwa. || Fabricated: Legal Norm | A quoted statutory passage attributed to 28 U.S.C. § 1924 in Doc.160 was a fabricated paraphrase presented as a direct quotation and does not match the statute's actual text.

Sanction teardown · D. Arizona, USA · 2026-07-28

Michael L. Ruiz v. Magellan Financial & Insurance Services (2)

What happened

In D. Arizona, USA, a filing relied on Claude AI to help draft legal argument. The court identified the following problems with the citations in that filing:

False Quotes (Case Law)

Two purported direct quotations attributed to Ninth Circuit cases (identified by counsel as Saman and Mitchell) in Plaintiff's response to defendant's fee motion (Doc.155) do not appear in those cases; counsel admitted she neglected to remove quotation marks.
False Quotes (Case Law)

Purported quotation attributed to United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001) in Plaintiff's 'Brief on Impeachment' (Doc.124) does not appear in Antonakeas.
False Quotes (Case Law)

Purported quotation attributed to United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009) in the same brief (Doc.124) does not appear in Osazuwa.
Fabricated (Legal Norm)

A quoted statutory passage attributed to 28 U.S.C. § 1924 in Doc.160 was a fabricated paraphrase presented as a direct quotation and does not match the statute's actual text.

Which AI tool

Claude AI. 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

Order to Show Cause

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/2746/Michael_L_Ruiz_Plaintiff_v_Magellan_Financial_And_Insurance_Services_Defen_USA_V9gvRhH.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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