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County of Los Angeles v. Neill Francis Niblett

Court
CA California
Jurisdiction
USA
Decided
2025-10-31
AI tool
Unidentified
Outcome
Show Cause Order
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Opening brief relied on an excerpt of Scripps Health (pp. 335–336) to assert threats must be immediate; the court explained the cited excerpt does not address that issue. || Fabricated: Case Law | Opening brief cited a non-existent case 'Montebello Unified School District v. State Board of Education (1991) 226 Cal.App.3d 1685'; counsel later conceded in a notice of errata that the citation does not appear to exist and attributed its inclusion to AI editing. || Fabricated: Case Law | Opening brief cited 'R.D. v. P.M. (2021) 68 Cal.App.5th 1012', a citation the County could not locate and the court concluded does not exist as presented. || Misrepresented: Case Law | Counsel misrepresented the holding of United States v. Rahimi, stating it invalidated a federal statute when Rahimi actually upheld the statute as applied in that case. || Misrepresented: Case Law | Counsel cited People v. Zermeno as supporting labor-speech protections and the proposition that strongly worded workplace criticism is protected, but Zermeno concerned gang-enhancement issues and does not support those propositions. || Misrepresented: Case Law | Brief cited Bookout v. Nielsen at page 1143 to claim reversal for lack of immediacy, but Bookout ends at page 1142 and the Court of Appeal affirmed the restraining order; counsel miscited and mischaracterized the case.

Sanction teardown · CA California, USA · 2025-10-31

County of Los Angeles v. Neill Francis Niblett

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:

  • Misrepresented (Case Law)
    Opening brief relied on an excerpt of Scripps Health (pp. 335–336) to assert threats must be immediate; the court explained the cited excerpt does not address that issue.
  • Fabricated (Case Law)
    Opening brief cited a non-existent case 'Montebello Unified School District v. State Board of Education (1991) 226 Cal.App.3d 1685'; counsel later conceded in a notice of errata that the citation does not appear to exist and attributed its inclusion to AI editing.
  • Fabricated (Case Law)
    Opening brief cited 'R.D. v. P.M. (2021) 68 Cal.App.5th 1012', a citation the County could not locate and the court concluded does not exist as presented.
  • Misrepresented (Case Law)
    Counsel misrepresented the holding of United States v. Rahimi, stating it invalidated a federal statute when Rahimi actually upheld the statute as applied in that case.
  • Misrepresented (Case Law)
    Counsel cited People v. Zermeno as supporting labor-speech protections and the proposition that strongly worded workplace criticism is protected, but Zermeno concerned gang-enhancement issues and does not support those propositions.
  • Misrepresented (Case Law)
    Brief cited Bookout v. Nielsen at page 1143 to claim reversal for lack of immediacy, but Bookout ends at page 1142 and the Court of Appeal affirmed the restraining order; counsel miscited and mischaracterized the case.

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

Show Cause Order

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/1000/Los_Angeles_v._Niblett_USA_31_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1000/Los_Angeles_v._Niblett_USA_31_October_2025.pdf

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