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Perez v. Schaal, et al.

Court
Super. Ct., Sacramento County (Cal.)
Jurisdiction
USA
Decided
2026-08-20
AI tool
Implied
Outcome
Court warned the pro se plaintiff to verify all citations and quotations, declined to impose sanctions at this time.
Monetary penalty
None reported

What was hallucinated

False Quotes: Case Law | Plaintiff attributed the sentence "The filing of an answer … effected a waiver of the right to demur." to Adorh (Adohr) Milk Farms, Inc. v. Love (255 Cal.App.2d 366), but the court could not find that language in that opinion or any reported case and noted the quotation may be AI-generated.

Details

The pro se plaintiff quoted a passage attributed to Adorh (Adohr) Milk Farms, Inc. v. Love (255 Cal.App.2d 366) that the court could not find in that opinion or any other reported case. The court identified the likely AI origin of the fabricated quotation, cited case law warning that relying on fabricated authority is sanctionable, and cautioned the plaintiff to verify citations. The court declined to impose sanctions at this time but warned future fabricated citations could result in sanctions.

Sanction teardown · Super. Ct., Sacramento County (Cal.), USA · 2026-08-20

Perez v. Schaal, et al.

What happened

In Super. Ct., Sacramento County (Cal.), 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:

  • False Quotes (Case Law)
    Plaintiff attributed the sentence "The filing of an answer … effected a waiver of the right to demur." to Adorh (Adohr) Milk Farms, Inc. v. Love (255 Cal.App.2d 366), but the court could not find that language in that opinion or any reported case and noted the quotation may be AI-generated.

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

Court warned the pro se plaintiff to verify all citations and quotations, declined to impose sanctions at this time.

Additional detail

The pro se plaintiff quoted a passage attributed to Adorh (Adohr) Milk Farms, Inc. v. Love (255 Cal.App.2d 366) that the court could not find in that opinion or any other reported case. The court identified the likely AI origin of the fabricated quotation, cited case law warning that relying on fabricated authority is sanctionable, and cautioned the plaintiff to verify citations. The court declined to impose sanctions at this time but warned future fabricated citations could result in sanctions.

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/3004/Perez_v._Schaal_USA_21_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/3004/Perez_v._Schaal_USA_21_August_2026.pdf

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