Sanction teardown · E.D. California, USA · 2025-09-09
Teniah Tercero v. Sacramento Logistics, LLC, et al.
What happened
In E.D. 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:
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Fabricated (Case Law)Counsel cited a nonexistent Seventh Circuit opinion; court found no such published Seventh Circuit opinion under that citation.
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False Quotes (Case Law)Attorney attributed a quotation to In re Loudermilch that does not appear there; court found the quoted language actually appears in Seedman (9th Cir.).
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False Quotes (Case Law)Counsel quoted language about lack of jurisdiction/compelling arbitration and attributed it to Atlantic Marine; the case discusses forum-selection clauses and does not contain the quoted language.
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False Quotes (Case Law)Counsel attributed a statement about liberal application of Rule 60(b)(6) to Ackermann; court found Ackermann does not contain that language.
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Misrepresented (Case Law)Counsel cited Tittjung as stating a judgment is void when rendered by a court lacking jurisdiction; court found Tittjung actually explains lack of subject-matter jurisdiction will not always render a judgment void, so the citation was misleading.
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Misrepresented (Case Law)Counsel quoted Beggerly as addressing Rule 60(b)(6); court found Beggerly does not discuss 60(b)(6) and the parenthetical was inaccurate.
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Fabricated (Case Law)Counsel cited a nonexistent Eleventh Circuit opinion; court searched reporters and found no such case or reporter entry.
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; Order to be server on client; State Bar notified (monetary penalty: 1500 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/777/Tercero_v._Sacramento_Logistics_USA_9_September_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).