What was hallucinated

Misrepresented: Case Law | Counsel cited 'Cardoso v. Soldo' with reporter information that actually corresponds to a different opinion (Lund v. Myers) and the cited authority did not support counsel's proposition. || Fabricated: Case Law | Counsel cited Arjona v. Arjona to support a proposition about orders of protection, but the Arjona memorandum decision did not involve domestic violence or an order of protection and was vacated. || Misrepresented: Case Law | Counsel cited Leon v. Plaza with incorrect reporter information and mischaracterized the case's holdings regarding naming specific incidents and statutory offenses. || False Quotes: Case Law | Counsel attributed quotations to Savord v. Morton that do not appear in that opinion; the court found the quoted language absent from Savord.

Details

The appellate court found Husband's counsel made multiple misleading or incorrect citations and attributed quotations to cases that do not contain them. The court noted some citations used incorrect reporters that pointed to unrelated decisions, concluded the cited authorities did not support counsel's propositions (and in some instances contradicted them), forwarded the decision to the State Bar for possible ethical violations, and awarded costs to the prevailing party.

Sanction teardown · CA Arizona, USA · 2025-08-07

Pineda v. Campos

What happened

In CA Arizona, 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:

Misrepresented (Case Law)

Counsel cited 'Cardoso v. Soldo' with reporter information that actually corresponds to a different opinion (Lund v. Myers) and the cited authority did not support counsel's proposition.
Fabricated (Case Law)

Counsel cited Arjona v. Arjona to support a proposition about orders of protection, but the Arjona memorandum decision did not involve domestic violence or an order of protection and was vacated.
Misrepresented (Case Law)

Counsel cited Leon v. Plaza with incorrect reporter information and mischaracterized the case's holdings regarding naming specific incidents and statutory offenses.
False Quotes (Case Law)

Counsel attributed quotations to Savord v. Morton that do not appear in that opinion; the court found the quoted language absent from Savord.

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

Referral to State bar; Ex officio adverse costs order (monetary penalty: 1 USD.)

Additional detail

The appellate court found Husband's counsel made multiple misleading or incorrect citations and attributed quotations to cases that do not contain them. The court noted some citations used incorrect reporters that pointed to unrelated decisions, concluded the cited authorities did not support counsel's propositions (and in some instances contradicted them), forwarded the decision to the State Bar for possible ethical violations, and awarded costs to the prevailing party.

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/1134/Pineda_v._Campos_USA_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).