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Bixler v. Church of Scientology

Court
CA California
Jurisdiction
USA
Decided
2026-02-19
AI tool
Unidentified
Outcome
Order to show cause
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | At least ten purported case authorities that have been miscited or mischaracterized in more than fifteen places in respondents’ brief.

Details

As later recounted by the defendant (see here), although counsel for the claimant confessed to AI misuse, the court of appeal did not address the matter in its subsequent opinion (see here), and the question is now before the state Supreme Court.

Sanction teardown · CA California, USA · 2026-02-19

Bixler v. Church of Scientology

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)
    At least ten purported case authorities that have been miscited or mischaracterized in more than fifteen places in respondents’ brief.

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

Order to show cause

Additional detail

As later recounted by the defendant (see here), although counsel for the claimant confessed to AI misuse, the court of appeal did not address the matter in its subsequent opinion (see here), and the question is now before the state Supreme Court.

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: Damien Charlotin's public AI Hallucination Cases Database (CC0).

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