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Creditors Adjustment Bureau, Inc. v. All Season Power LLC, et al.

Court
C.D. California
Jurisdiction
USA
Decided
2026-02-13
AI tool
Unidentified
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff's counsel cited a non-existent (phantom) case in its brief; counsel later admitted the citation was from a non-existent case produced by AI-assisted research and the court noted the error. || False Quotes: Case Law | Plaintiff's counsel included a quoted passage attributed to a real case, but the quote does not exist in the source—one of three phantom quotes identified in counsel's declaration. || False Quotes: Case Law | A second non-existent quotation was attributed to an existing case in Plaintiff's brief; counsel admitted the quote was erroneous and tied the error to AI-assisted research. || False Quotes: Case Law | A third non-existent quotation (attributed to a real case) was identified; Defendant later acknowledged that one of the same erroneous citations appeared in its reply brief.

Sanction teardown · C.D. California, USA · 2026-02-13

Creditors Adjustment Bureau, Inc. v. All Season Power LLC, et al.

What happened

In C.D. 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)
    Plaintiff's counsel cited a non-existent (phantom) case in its brief; counsel later admitted the citation was from a non-existent case produced by AI-assisted research and the court noted the error.
  • False Quotes (Case Law)
    Plaintiff's counsel included a quoted passage attributed to a real case, but the quote does not exist in the source—one of three phantom quotes identified in counsel's declaration.
  • False Quotes (Case Law)
    A second non-existent quotation was attributed to an existing case in Plaintiff's brief; counsel admitted the quote was erroneous and tied the error to AI-assisted research.
  • False Quotes (Case Law)
    A third non-existent quotation (attributed to a real case) was identified; Defendant later acknowledged that one of the same erroneous citations appeared in its reply 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

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://reason.com/volokh/2026/03/17/perhaps-due-to-the-asynchronous-thelma-and-louise-neither-side-requests-sanctions/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://reason.com/volokh/2026/03/17/perhaps-due-to-the-asynchronous-thelma-and-louise-neither-side-requests-sanctions/

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