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Fabricated — does not exist

Corrigan v. City of Scottsdale does not exist — a fabricated AI citation

Cited as: 720 F.3d 513, 520 (9th Cir. 2013)

This case is fabricated

A plaintiff's emergency motion for a temporary restraining order in Holmes v. Cape Meadows Apartments HRMS cited “Corrigan v. City of Scottsdale, 720 F.3d 513, 520 (9th Cir. 2013)” as Ninth Circuit authority. The U.S. District Court for the Eastern District of Missouri found the citation fabricated, and separately noted the motion appeared to have been drafted using generative AI — it contained unfilled bracketed placeholders alongside the fake case.

The fabrication here follows a specific, identifiable pattern: the volume and starting page — 720 and 513 — exactly match a real, genuine case, just not the one cited. Corrigan v. City of Scottsdale is an actual, decided matter, twice over: a 1986 Arizona Supreme Court ruling reported at 720 P.2d 513, 149 Ariz. 538, and a related 1985 Arizona Court of Appeals decision at 720 P.2d 528. Both are Arizona state-court environmental-law rulings reported in the Pacific Reporter — not the Federal Reporter, not the Ninth Circuit, and not 2013.

This is a textbook reporter-hijacking hallucination: the same numbers, a plausible-sounding federal reporter abbreviation swapped in for the real state one, and a jurisdiction and year that fit the surrounding brief. The court, for reasons of judicial efficiency, addressed the underlying TRO motion on the merits anyway, denied it, and dismissed the case under 28 U.S.C. § 1915(e)(2)(B) without imposing a separate monetary sanction for the fabricated citation.

Real cases with similar names

Verified against the CourtListener case-law database. These are real, existing decisions — do not confuse them with the fabricated citation above.

  • Corrigan v. City of Scottsdale

    720 P.2d 513, 149 Ariz. 538 (Ariz. 1986) · Arizona Supreme Court · June 2, 1986

    A real Arizona Supreme Court environmental-law decision. Note the identical volume and starting page number (720/513) to the fabricated citation — but Pacific Reporter, Arizona state court, and 1986, not Federal Reporter, Ninth Circuit, and 2013.

  • Corrigan v. City of Scottsdale

    720 P.2d 528, 149 Ariz. 553 (Ariz. Ct. App. 1985) · Arizona Court of Appeals · February 28, 1985

    A related real Arizona Court of Appeals ruling in the same underlying dispute, also unrelated to the fabricated federal citation.

How to verify a case citation

A citation is only as good as its weakest link: the case has to exist, the quote attributed to it has to actually appear in the opinion, and the opinion has to actually support the proposition it's cited for. Deterministic verification checks each of those three things against a primary source — a real court docket or reporter, not another AI's guess — so the result does not depend on whether the tool doing the checking might itself hallucinate. That is the only way to catch a fabricated citation like this one before it reaches a filing rather than after a judge does.

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This entry documents a fabricated citation identified in a real, publicly reported court ruling. It is informational only, not legal advice. Corrections: /contact.

Written by the Citation Safe Research Desk · Reviewed by Andy Gaber, Founder