Sanction teardown · D. Arizona, USA · 2026-03-31
Chelsea Montes v. Suns Legacy Partners LLC
What happened
In D. Arizona, 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:
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Fabricated (Case Law)Response to motion to dismiss included 'McIntyre v. Phx. Newspapers, Inc.' citation that was fabricated/mis-cited as filed.
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Fabricated (Case Law)Reply in support of anonymity contained multiple 'Doe v. ...' citations (e.g., Amazon) presented with Westlaw/West reporter info that did not exist as cited and were removed or corrected.
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Fabricated (Case Law)Reply included 'Doe v. Maricopa County Community College District, 2017 WL 4460441 (D. Ariz. Oct. 5, 2017)' that counsel could not identify as a real corresponding opinion; court treated it as fabricated.
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Fabricated (Case Law)Reply cited 'Doe v. Northrop Grumman Sys. Corp., 2022 WL 3447983 (E.D. Va. Aug. 17, 2022)' as authority; court found the citation was misreferenced/ fabricated as used.
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Fabricated (Case Law)Initial complaint cited a non-existent case and parenthetical about Equal Pay Act plausibility; court found the citation fictitious.
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Fabricated (Case Law)Response to motion to dismiss cited 'Pizzo v. City of Chandler' as a 2021 D. Ariz. opinion; court determined the citation was fabricated as presented.
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False Quotes (Case Law)Filings contained quoted phrases attributed to Ahanchian that did not appear verbatim in the opinion; court found they were paraphrased or presented as false quotations.
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False Quotes (Case Law)Filings included fabricated/direct-quotation-style phrases attributed to other real cases (e.g., Briones, Sibley, Valley Eng'rs) that were not direct quotes in those opinions.
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
Adverse Costs Order; CLE; Notification
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/1872/Montes_v._Suns_Legacy_Partners_USA_31_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).