What was hallucinated

False Quotes: Case Law | Rios misquoted language from ten existing cases; the court found the quoted language appears nowhere in those decisions (including purported quotations from Osumi v. Sutton (2007) and Fiore v. Alvord (1985)). || Fabricated: Case Law | Rios cited a non-existent opinion as "Stanley v. Univ. of Southern California (2022) 98 Cal.App.5th 151"; the court found that citation incorrect/not corresponding to an existing 2022 Cal.App.5th reporter opinion. || Fabricated: Case Law | Rios cited a non-existent opinion as "Eustace v. Lynch (2012) 209 Cal.App.4th 1457"; the court found that citation incorrect/not corresponding to an existing 2012 Cal.App.4th reporter opinion.

Sanction teardown · CA California, USA · 2026-02-17

Alejandro Rios v. Puente Hills Ford

What happened

In CA 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:

False Quotes (Case Law)

Rios misquoted language from ten existing cases; the court found the quoted language appears nowhere in those decisions (including purported quotations from Osumi v. Sutton (2007) and Fiore v. Alvord (1985)).
Fabricated (Case Law)

Rios cited a non-existent opinion as "Stanley v. Univ. of Southern California (2022) 98 Cal.App.5th 151"; the court found that citation incorrect/not corresponding to an existing 2022 Cal.App.5th reporter opinion.
Fabricated (Case Law)

Rios cited a non-existent opinion as "Eustace v. Lynch (2012) 209 Cal.App.4th 1457"; the court found that citation incorrect/not corresponding to an existing 2012 Cal.App.4th reporter opinion.

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

Warning

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/1536/Rios_v._Puente_Hills_Ford_USA_17_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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