What was hallucinated

Fabricated: Case Law | Plaintiff cited Spokane v. Douglass, 800 F.3d 1075 (2015), for ‘under color of state law’; the court found no such case exists and that the citation corresponds to Avendano-Hernandez v. Lynch, which does not address that topic. || Fabricated: Case Law | Plaintiff cited Hummel v. State, 833 P.2d 1370 (Nev. 1992), for stalking principles; the court found no Nevada case by that name and that the citation corresponds to State v. Dotter (Or.), unrelated to stalking. || False Quotes: Case Law | Plaintiff quoted Hearns v. San Bernardino Police Dep’t for a Rule 8 standard the court says is not in that case or any other.

Details

AI UseThe plaintiff submitted citations that were entirely fabricated. When challenged, Saxena denied AI use and insisted the cases existed, offering no evidence. The court concluded either he fabricated the citations or relied on AI and failed to verify them.Hallucination DetailsSpokane v. Douglass turned out to conflate unrelated decisions and misused citations from other casesHummel v. State could not be found in any Nevada or national database; citation matched an unrelated Oregon caseThe court found no plausible explanation for these citations other than AI generation or outright fabrication.Ruling/SanctionThe court dismissed the case with prejudice for repeated failure to comply with Rule 8 and for the submission of fictitious citations. Though no separate sanctions motion was granted, the court's ruling incorporated the AI misuse into its reasoning and concluded that Saxena could not be trusted to proceed further in good faith.Key Judicial ReasoningCiting Morgan v. Cmty. Against Violence, the court reasoned that “courts do not make allowances for a plaintiff who cites to fake, nonexistent, misleading authorities.” Saxena’s refusal to acknowledge the fabrication compounded the issue. In a subsequent order, the court held that being pro se and disabled "is no excuse for submitting non-existent authority to the court in support of a brief".

Sanction teardown · D. Nevada, USA · 2025-02-18

Saxena v. Martinez-Hernandez et al.

What happened

In D. Nevada, 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)

Plaintiff cited Spokane v. Douglass, 800 F.3d 1075 (2015), for ‘under color of state law’; the court found no such case exists and that the citation corresponds to Avendano-Hernandez v. Lynch, which does not address that topic.
Fabricated (Case Law)

Plaintiff cited Hummel v. State, 833 P.2d 1370 (Nev. 1992), for stalking principles; the court found no Nevada case by that name and that the citation corresponds to State v. Dotter (Or.), unrelated to stalking.
False Quotes (Case Law)

Plaintiff quoted Hearns v. San Bernardino Police Dep’t for a Rule 8 standard the court says is not in that case or any other.

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

Complaint dismissed with prejudice; no formal AI-related sanction imposed, but dismissal explicitly acknowledged fictitious citations as contributing factor

Additional detail

AI UseThe plaintiff submitted citations that were entirely fabricated. When challenged, Saxena denied AI use and insisted the cases existed, offering no evidence. The court concluded either he fabricated the citations or relied on AI and failed to verify them.Hallucination DetailsSpokane v. Douglass turned out to conflate unrelated decisions and misused citations from other casesHummel v. State could not be found in any Nevada or national database; citation matched an unrelated Oregon caseThe court found no plausible explanation for these citations other than AI generation or outright fabrication.Ruling/SanctionThe court dismissed the case with prejudice for repeated failure to comply with Rule 8 and for the submission of fictitious citations. Though no separate sanctions motion was granted, the court's ruling incorporated the AI misuse into its reasoning and concluded that Saxena could not be trusted to proceed further in good faith.Key Judicial ReasoningCiting Morgan v. Cmty. Against Violence, the court reasoned that “courts do not make allowances for a plaintiff who cites to fake, nonexistent, misleading authorities.” Saxena’s refusal to acknowledge the fabrication compounded the issue. In a subsequent order, the court held that being pro se and disabled "is no excuse for submitting non-existent authority to the court in support of a brief".

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/313/Saxena_v._Martinez-Hernandez_et_al_D._Nev_February_18_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).