What was hallucinated

False Quotes: Case Law | Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion. || Fabricated: Legal Norm | Mother's brief quoted A.R.S. § 8-531(1) as stating: '[a]bandonment is measured by a parent's conduct, not the parent's subjective intent.' The court found this quoted statutory language does not appear in § 8-531(1). || Fabricated: Legal Norm | Mother's brief attributed language to A.R.S. § 8-533(B)(1) stating abandonment is established when a parent has failed to maintain a normal parental relationship 'without just cause.' The court found the statute does not contain the quoted phrasing. || False Quotes: Case Law | Mother's brief attributed a non-existent quote to Raymond F. v. Dep't of Econ. Sec., 224 Ariz. 373, 378, ¶ 21 (App. 2010): '[a] parent who creates barriers to contact through substance abuse cannot claim just cause for his failure to maintain a relationship.' The court found this quotation does not appear in Raymond F.

Sanction teardown · CA Arizona, USA · 2026-02-25

In re termination of parental rights (HK)

What happened

In CA Arizona, 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:

False Quotes (Case Law)

Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion.
Fabricated (Legal Norm)

Mother's brief quoted A.R.S. § 8-531(1) as stating: '[a]bandonment is measured by a parent's conduct, not the parent's subjective intent.' The court found this quoted statutory language does not appear in § 8-531(1).
Fabricated (Legal Norm)

Mother's brief attributed language to A.R.S. § 8-533(B)(1) stating abandonment is established when a parent has failed to maintain a normal parental relationship 'without just cause.' The court found the statute does not contain the quoted phrasing.
False Quotes (Case Law)

Mother's brief attributed a non-existent quote to Raymond F. v. Dep't of Econ. Sec., 224 Ariz. 373, 378, ¶ 21 (App. 2010): '[a] parent who creates barriers to contact through substance abuse cannot claim just cause for his failure to maintain a relationship.' The court found this quotation does not appear in Raymond F.

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/1584/In_re_termination_of_parental_rights_USA_25_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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