Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 17, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · CA Arizona (1d), USA · 2026-09-17

Varela v. Hauser

What happened

In CA Arizona (1d), 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)

Wife cited In re Marriage of Balsige as authority that a trial court abuses its discretion by relying on unadmitted materials. The court found no such case in any jurisdiction; the reporter citation instead referred to Elgin, which addressed federal preemption and did not support the quoted proposition.
Misrepresented (Case Law)

Wife cited State v. McCray for the proposition that demonstrative aids are not evidence and cannot support factual findings. The court reviewed McCray and found that it concerned authentication of DNA evidence and did not mention demonstrative aids.
Misrepresented (Case Law)

Wife cited State v. Martin for the proposition that demonstrative aids are not evidence and cannot support factual findings. The court found that Martin concerned prejudice under fundamental-error review in a criminal case and did not mention demonstrative aids.

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

Action forfeited

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/3117/VARELA_v._HAUSER_USA_17_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).