What was hallucinated

Fabricated: Case Law | Appellant quoted Lilienthal as stating tests for distinct claims ('(1) times of services performed; (2) specific obligations involved; and (3) resulting damages'), but the quotation does not appear in Lilienthal and the case does not address settlement offsets. || Fabricated: Case Law | Appellant quoted Rudick as stating that failure to respond waives an objection; the cited Rudick decision does not include that quotation. || Fabricated: Case Law | Appellant attributed a quotation about using extrinsic evidence to interpret a settlement reached in mediation (with arbitration clause) to Riverisland; the quoted language does not appear in Riverisland. || Fabricated: Case Law | Appellant attributed an objective-contract interpretation quotation to Leaf v. City of San Mateo; the Leaf opinion does not contain the quoted language and did not involve a contested contract. || Fabricated: Case Law | Appellant cited Milstein for the proposition 'a judgment by default admits all material allegations of the complaint,' but Milstein does not contain that language as quoted. || Fabricated: Case Law | Multiple additional fabricated quotations and inaccurate descriptions of legal authorities appeared across the opening and reply briefs, attributed by counsel to use of an AI system that altered citations during word-count reduction.

Sanction teardown · CA California, USA · 2026-02-18

EFD USA, INC., et al. v. Band Pro Film and Digital, Inc., et al.

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)

Appellant quoted Lilienthal as stating tests for distinct claims ('(1) times of services performed; (2) specific obligations involved; and (3) resulting damages'), but the quotation does not appear in Lilienthal and the case does not address settlement offsets.
Fabricated (Case Law)

Appellant quoted Rudick as stating that failure to respond waives an objection; the cited Rudick decision does not include that quotation.
Fabricated (Case Law)

Appellant attributed a quotation about using extrinsic evidence to interpret a settlement reached in mediation (with arbitration clause) to Riverisland; the quoted language does not appear in Riverisland.
Fabricated (Case Law)

Appellant attributed an objective-contract interpretation quotation to Leaf v. City of San Mateo; the Leaf opinion does not contain the quoted language and did not involve a contested contract.
Fabricated (Case Law)

Appellant cited Milstein for the proposition 'a judgment by default admits all material allegations of the complaint,' but Milstein does not contain that language as quoted.
Fabricated (Case Law)

Multiple additional fabricated quotations and inaccurate descriptions of legal authorities appeared across the opening and reply briefs, attributed by counsel to use of an AI system that altered citations during word-count reduction.

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

Monetary Sanction (monetary penalty: 900 USD.)

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/1552/EFD_USA_v_BAND_PRO_FILM_AND_DIGITAL_IN_USA_18_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template