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Yasiel Puig Valdes v. All3Media America, LLC, et al.

Court
SCA California (Los Angeles)
Jurisdiction
USA
Decided
2025-10-15
AI tool
ChatGPT
Outcome
Referral
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Opposition cited a non-existent case 'Edwards v. Hearst Corp. (1991) 53 Cal.3d 30, 43'; court confirmed it does not exist and counsel admitted it appeared after using ChatGPT. || Fabricated: Case Law | Opposition cited a non-existent case 'Heath v. San Joaquin Comm. Hosp. Dist. (1993) 15 Cal.App.4th 708, 713-14'; court confirmed it does not exist and counsel admitted it came from ChatGPT.

Sanction teardown · SCA California (Los Angeles), USA · 2025-10-15

Yasiel Puig Valdes v. All3Media America, LLC, et al.

What happened

In SCA California (Los Angeles), USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Opposition cited a non-existent case 'Edwards v. Hearst Corp. (1991) 53 Cal.3d 30, 43'; court confirmed it does not exist and counsel admitted it appeared after using ChatGPT.
  • Fabricated (Case Law)
    Opposition cited a non-existent case 'Heath v. San Joaquin Comm. Hosp. Dist. (1993) 15 Cal.App.4th 708, 713-14'; court confirmed it does not exist and counsel admitted it came from ChatGPT.

Which AI tool

ChatGPT. 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

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://reason.com/volokh/2025/10/27/yasiel-puig-ai-hallucinated-citations-gambling-and-libel/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://reason.com/volokh/2025/10/27/yasiel-puig-ai-hallucinated-citations-gambling-and-libel/

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