What was hallucinated

Fabricated: Case Law | Appellant cited this case to argue suicidal ideation cannot constitute abuse under the DVPA; appellate court found 'Quinn v. Levine (2021) 62 Cal.App.5th 366' to be fictitious/unlocatable and did not rely on it. || Fabricated: Case Law | Appellant relied on this authority to support her position on DVPA scope; the court was unable to locate 'In re Marriage of L.B. (2018) 30 Cal.App.5th 1076' and treated the citation as incorrect/unreliable. || Fabricated: Case Law | Appellant cited this decision in support of her arguments; the appellate court could not find 'In re Marriage of C.T. and R.T. (2017) 12 Cal.App.5th 982' and rejected reliance on it. || Fabricated: Case Law | Appellant cited this Supreme Court authority which the court could not locate as supporting authority; treated as an incorrect citation. || Fabricated: Case Law | Appellant cited this case for propositions on abuse/neglect; appellate court could not find 'In re Marriage of Mathews (2005) 133 Cal.App.4th 1407' and did not accept it as authority. || Fabricated: Case Law | Appellant relied on this citation for DVPA-related propositions; the court was unable to locate 'In re Marriage of Facter (2016) 1 Cal.App.5th 526' and treated it as erroneous. || Fabricated: Case Law | Appellant cited this case (with inconsistent citations) to support claims about separation/date issues; the appellate court could not locate 'In re Marriage of Manfer (2006) 144 Cal.App.4th 925' as cited and noted citation problems.

Details

The appellate opinion and editor's note identify numerous incorrect or non-existent case citations in the appellant's filings. The court treated those citations as unreliable, found several to be fictitious or unlocatable, and declined to credit them in resolving the appeals.

Sanction teardown · CA California, USA · 2025-09-30

In re the Marriage of D.X. and S.P.

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 cited this case to argue suicidal ideation cannot constitute abuse under the DVPA; appellate court found 'Quinn v. Levine (2021) 62 Cal.App.5th 366' to be fictitious/unlocatable and did not rely on it.
Fabricated (Case Law)

Appellant relied on this authority to support her position on DVPA scope; the court was unable to locate 'In re Marriage of L.B. (2018) 30 Cal.App.5th 1076' and treated the citation as incorrect/unreliable.
Fabricated (Case Law)

Appellant cited this decision in support of her arguments; the appellate court could not find 'In re Marriage of C.T. and R.T. (2017) 12 Cal.App.5th 982' and rejected reliance on it.
Fabricated (Case Law)

Appellant cited this Supreme Court authority which the court could not locate as supporting authority; treated as an incorrect citation.
Fabricated (Case Law)

Appellant cited this case for propositions on abuse/neglect; appellate court could not find 'In re Marriage of Mathews (2005) 133 Cal.App.4th 1407' and did not accept it as authority.
Fabricated (Case Law)

Appellant relied on this citation for DVPA-related propositions; the court was unable to locate 'In re Marriage of Facter (2016) 1 Cal.App.5th 526' and treated it as erroneous.
Fabricated (Case Law)

Appellant cited this case (with inconsistent citations) to support claims about separation/date issues; the appellate court could not locate 'In re Marriage of Manfer (2006) 144 Cal.App.4th 925' as cited and noted citation problems.

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

Warning

Additional detail

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/838/In_re_the_Marriage_of_DX_and_SP_DX_v_SP_USA_30_September_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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