What was hallucinated

Fabricated: Case Law | Defendants identified 'Younger v. City of Seattle, 70 F.4th 1099, 1107 (9th Cir. 2023)' as a nonexistent Ninth Circuit citation; 70 F.4th 1099 corresponds to an unrelated Eighth Circuit case and no Ninth Circuit case with that title appears to exist. || Fabricated: Case Law | Thornton cited 'United States v. Craner, 652 F. App'x 560, 562 (9th Cir. 2016)'; the Court noted this citation appears incorrect/nonexistent as cited and may reflect a miscitation (perhaps meant 652 F.2d 23 (9th Cir. 1981)), which does not support Thornton's asserted proposition. || Fabricated: Case Law | Thornton cited 'United States v. Smith, 629 F.3d 1082, 1084 (9th Cir. 2011)'; the Court identified this citation as nonexistent in the form cited and treated it as a fabricated authority in Thornton's briefing. || False Quotes: Case Law | Thornton quoted language attributed to Odd v. Malone, 538 F.3d 202 (3d Cir. 2008); the Court found the quoted language is not in that opinion and the opinion was not authored by the judge Thornton referenced (misquoted/misattributed).

Sanction teardown · D. Montana, USA · 2026-01-23

Dennis Thornton v. Flathead County, et al.

What happened

In D. Montana, 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)

Defendants identified 'Younger v. City of Seattle, 70 F.4th 1099, 1107 (9th Cir. 2023)' as a nonexistent Ninth Circuit citation; 70 F.4th 1099 corresponds to an unrelated Eighth Circuit case and no Ninth Circuit case with that title appears to exist.
Fabricated (Case Law)

Thornton cited 'United States v. Craner, 652 F. App'x 560, 562 (9th Cir. 2016)'; the Court noted this citation appears incorrect/nonexistent as cited and may reflect a miscitation (perhaps meant 652 F.2d 23 (9th Cir. 1981)), which does not support Thornton's asserted proposition.
Fabricated (Case Law)

Thornton cited 'United States v. Smith, 629 F.3d 1082, 1084 (9th Cir. 2011)'; the Court identified this citation as nonexistent in the form cited and treated it as a fabricated authority in Thornton's briefing.
False Quotes (Case Law)

Thornton quoted language attributed to Odd v. Malone, 538 F.3d 202 (3d Cir. 2008); the Court found the quoted language is not in that opinion and the opinion was not authored by the judge Thornton referenced (misquoted/misattributed).

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 file conventional hard-copy source documents for every cited authority

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/1377/Thornton_v._Flathead_County_USA_23_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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