Sanction teardown · CA California (4d), USA · 2026-07-02

Patterson v. Nuvision Credit Union

What happened

In CA California (4d), 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)
  Opening brief cited a 1961 California appellate decision that does not appear to exist as cited.
• False Quotes (Case Law)
  Attributed a quotation to Romero that the court found does not appear in that opinion.
• False Quotes (Case Law)
  Attributed a quotation to Tweel that the court found does not appear in that opinion.
• Fabricated (Case Law)
  Opening brief cited a Seventh Circuit case that does not appear to exist.
• Fabricated (Case Law)
  Opening brief cited a Fifth Circuit unpublished opinion that does not appear to exist.
• Fabricated (Case Law)
  Opening brief cited a bankruptcy decision that does not appear to exist.
• False Quotes (Case Law)
  Attributed a quotation to Strong v. County of Santa Cruz that the court found does not appear in that opinion.
• False Quotes (Case Law)
  Attributed a quotation to Lake v. Reed that the court found does not appear in that opinion.
• Misrepresented (Case Law)
  Cited Romero (a criminal case) for the proposition that UCC provisions are binding, which the court found to be an inapposite or misrepresented use of that authority.
• Fabricated (Case Law)
  Opening brief cited a purported bankruptcy decision reported in a UCC service that does not appear to exist.
• Fabricated (Case Law)
  Opening brief cited a non-existent bankruptcy memorandum opinion by docket reference.
• Fabricated (Case Law)
  Opening brief cited a California appellate decision that does not appear to exist as cited.

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

Monetary sanction; Bar Referral (UPL) (monetary penalty: 500 USD.)

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/2531/Patterson_v._Digital_Federal_Credit_Union_USA_2_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).