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Gharavi v. Google LLC

Court
N.D. California
Jurisdiction
USA
Decided
2026-01-12
AI tool
Bloomberg Law
Outcome
Motion for Sanctions denied
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Counsel included a non-existent Wisconsin case in a sworn declaration; court found counsel relied on Bloomberg Law and the error was inadvertent and not in bad faith.

Details

Rodgers' declaration included a non-existent Wisconsin criminal case citation (reported by Bloomberg Law). Court found the error inadvertent, attributable to reliance on Bloomberg, and denied sanctions because conduct was neither reckless nor in bad faith.

Sanction teardown · N.D. California, USA · 2026-01-12

Gharavi v. Google LLC

What happened

In N.D. California, USA, a filing relied on Bloomberg Law to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Counsel included a non-existent Wisconsin case in a sworn declaration; court found counsel relied on Bloomberg Law and the error was inadvertent and not in bad faith.

Which AI tool

Bloomberg Law. 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

Motion for Sanctions denied

Additional detail

Rodgers' declaration included a non-existent Wisconsin criminal case citation (reported by Bloomberg Law). Court found the error inadvertent, attributable to reliance on Bloomberg, and denied sanctions because conduct was neither reckless nor in bad faith.

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/1394/Gharavi_v_Google_LLC.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1394/Gharavi_v_Google_LLC.pdf

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