What was hallucinated

Fabricated: Case Law | Court and counsel cited 'Marriage of Twigg' as authority on prioritizing parties' emotional well‑being in custody; Twigg does not exist and the citation "34 Cal.3d 926" and parallel citations provided by counsel were fabricated. Court found reliance on this nonexistent authority and counsel later admitted Twigg was fictitious. || Misrepresented: Case Law | Counsel cited 'In re Marriage of Teegarden' with an incorrect citation/year and attributed a holding about emotional well‑being and pet custody that the real 1986 Teegarden decision did not hold; the citation and asserted holding were misrepresented.

Sanction teardown · CA California, USA · 2026-03-05

Joan Pablo Torres Campos v. Leslie Ann Munoz

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)

Court and counsel cited 'Marriage of Twigg' as authority on prioritizing parties' emotional well‑being in custody; Twigg does not exist and the citation "34 Cal.3d 926" and parallel citations provided by counsel were fabricated. Court found reliance on this nonexistent authority and counsel later admitted Twigg was fictitious.
Misrepresented (Case Law)

Counsel cited 'In re Marriage of Teegarden' with an incorrect citation/year and attributed a holding about emotional well‑being and pet custody that the real 1986 Teegarden decision did not hold; the citation and asserted holding were misrepresented.

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

Monetary sanction; Bar referral (monetary penalty: 5000 USD.)

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/1599/D085584.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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