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FHMC, LLC et al. v. Blue Cross and Blue Shield of Arizona, Inc.

Court
CA Arizona (1d)
Jurisdiction
USA
Decided
2026-06-22
AI tool
Implied
Outcome
Bar Referral
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Appellant cited 'Arnal v. Travelers Prop. Cas. Ins. Co.' with a 2007 LEXIS citation that the court determined does not exist in the reported form provided. || Fabricated: Case Law | Appellant cited a nonexistent LexisNexis reporter citation for Mod. Orthopaedics of NJ v. Premera Blue Cross; court found the '2025 LX 425206 (D.N.J. Nov. 3, 2025)' reporter citation does not exist. || Fabricated: Case Law | Appellant cited a non-existent LEXIS entry for the same D.N.J. decision; court identified '2025 U.S. Dist. LEXIS 215824 (D.N.J. Nov. 3, 2025)' as not existing. || Fabricated: Case Law | Appellant relied on a purported S.D.N.Y. LEXIS decision 'Kennedy v. UnitedHealth Grp. Inc.' with a 2025 LEXIS citation which the court found does not exist. || Fabricated: Case Law | Appellant cited a Lexis citation for the federal district court order in this litigation that the court identified as nonexistent: '2024 U.S. Dist. LEXIS 62018'.

Sanction teardown · CA Arizona (1d), USA · 2026-06-22

FHMC, LLC et al. v. Blue Cross and Blue Shield of Arizona, Inc.

What happened

In CA Arizona (1d), 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 cited 'Arnal v. Travelers Prop. Cas. Ins. Co.' with a 2007 LEXIS citation that the court determined does not exist in the reported form provided.
  • Fabricated (Case Law)
    Appellant cited a nonexistent LexisNexis reporter citation for Mod. Orthopaedics of NJ v. Premera Blue Cross; court found the '2025 LX 425206 (D.N.J. Nov. 3, 2025)' reporter citation does not exist.
  • Fabricated (Case Law)
    Appellant cited a non-existent LEXIS entry for the same D.N.J. decision; court identified '2025 U.S. Dist. LEXIS 215824 (D.N.J. Nov. 3, 2025)' as not existing.
  • Fabricated (Case Law)
    Appellant relied on a purported S.D.N.Y. LEXIS decision 'Kennedy v. UnitedHealth Grp. Inc.' with a 2025 LEXIS citation which the court found does not exist.
  • Fabricated (Case Law)
    Appellant cited a Lexis citation for the federal district court order in this litigation that the court identified as nonexistent: '2024 U.S. Dist. LEXIS 62018'.

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

Bar Referral

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/2497/FHMC_et_al._v._BLUE_CROSS_USA_22_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2497/FHMC_et_al._v._BLUE_CROSS_USA_22_June_2026.pdf

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