What was hallucinated

Fabricated: Case Law | Appellant cited 'County of Sacramento v. Superior Court (2014) 232 Cal.App.4th 305' as controlling authority; the court determined this case citation does not exist and does not support appellant's proposition. || Fabricated: Legal Norm | Appellant cited 'Government Code section 911.5, subdivision (b)' to support due process arguments; the court found this statutory citation (as cited) to be nonexistent or inaccurately relied upon by appellant. || Fabricated: Other | The court identified that at least 11 authorities in appellant's briefs were either nonexistent or wholly inaccurate and attributed the errors to fabrication or failure to review citations potentially produced by generative AI.

Sanction teardown · CA California, USA · 2026-02-25

Anthony Jama Hall v. Superior Court of Sacramento County

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:

Fabricated (Case Law)

Appellant cited 'County of Sacramento v. Superior Court (2014) 232 Cal.App.4th 305' as controlling authority; the court determined this case citation does not exist and does not support appellant's proposition.
Fabricated (Legal Norm)

Appellant cited 'Government Code section 911.5, subdivision (b)' to support due process arguments; the court found this statutory citation (as cited) to be nonexistent or inaccurately relied upon by appellant.
Fabricated (Other)

The court identified that at least 11 authorities in appellant's briefs were either nonexistent or wholly inaccurate and attributed the errors to fabrication or failure to review citations potentially produced by generative AI.

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.

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Source: https://www.damiencharlotin.com/documents/1585/Jama_Hall_v._Superior_Court_USA_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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