Sanction teardown · N.D. California, USA · 2026-02-17
In re: Social Media Adolescent Addiction Litigation
What happened
In N.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:
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Fabricated (Doctrinal Work)Deposition admission that some academic articles cited by Osborne do not exist; defendants attribute those citations to AI-generated fabrications; court noted plaintiffs said citations were corrected and declined to exclude the expert on that basis.
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Misrepresented (Other)Other incorrect/miscited references in Osborne's report attributed to use of an AI citation tool; court treated these as citation-formatting errors, not grounds for exclusion, and allowed cross-examination.
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
Court declined to exclude the expert based on the AI-generated/incorrect citations; issue reserved for cross-examination; motion to exclude denied.
Additional detail
Defendants contended that Dr. Brian Osborne relied on nonexistent academic articles and miscited sources generated by an AI citation tool. Plaintiffs said the errors were formatting miscites from an AI citation tool and were corrected. The Court declined to exclude Osborne's opinions on this basis, permitting defendants to explore the issue on cross-examination and barring any regurgitation of hearsay at trial.
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.
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Source: https://www.damiencharlotin.com/documents/1604/Social_Media_Litigation_USA_17_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).