What was hallucinated

Fabricated: Case Law | Appellant cited a nonexistent case 'In re Marriage of Handley' to support that the standard of review is abuse of discretion; court identified it as fictitious, noted it was removed in corrected filings, and treated the citation as sanctionable conduct but declined sanctions. || Fabricated: Case Law | Appellant cited a nonexistent case 'In re Marriage of Akins' to support that substantial wealth disparity factors into forum convenience; court identified it as fictitious, warned against AI-generated fictitious cases, and noted the citation was corrected.

Details

The appellant (self-represented) cited two nonexistent cases in her appellate brief. The respondent flagged the fictitious citations and requested sanctions. The court found the citations fictitious, discussed sanction authority and AI-generated filings, but declined to impose sanctions because the request was procedurally inappropriate, the appellant corrected filings promptly, and the legal propositions were, in fact, supported by existing authority.

Sanction teardown · CA California, USA · 2025-09-15

Nga Huynh v. Joseph Desimone

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:

Fabricated (Case Law)

Appellant cited a nonexistent case 'In re Marriage of Handley' to support that the standard of review is abuse of discretion; court identified it as fictitious, noted it was removed in corrected filings, and treated the citation as sanctionable conduct but declined sanctions.
Fabricated (Case Law)

Appellant cited a nonexistent case 'In re Marriage of Akins' to support that substantial wealth disparity factors into forum convenience; court identified it as fictitious, warned against AI-generated fictitious cases, and noted the citation was corrected.

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

Warning

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.

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Source: https://www.damiencharlotin.com/documents/798/NGA_HUYNH_Plaintiff_and_Appellant_v_JOSEPH_DESIMONE_JR_Defendant_and_Respondent.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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