Sanction teardown · E.D. California, USA · 2025-12-03
Juan Villalovos-Gutierrez, et al. v. Gerard Van De Pol (1)
What happened
In E.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 (Case Law)Court found the citation “Ho v. Ernst & Young LLP, 2011 WL 7106622, at *2 (C.D. Cal. Dec. 19, 2011)” to be incorrect or not supporting the asserted proposition; flagged as possibly fictitious or mis-cited.
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Fabricated (Case Law)Court observed “Lobaton v. City of San Diego, No. 3:15-cv-1416-GPC-DHB, *2020 WL 7334512, at 4 (S.D. Cal. Dec. 14, 2020)” appeared to be mis-cited or not a real/accurate authority for the proposition offered.
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Fabricated (Case Law)Court identified “Gonzalez v. CoreCivic, Inc., No. 1:18-cv-00927-DAD-EPG, *2020 WL 4437167, at 3 (E.D. Cal. July 31, 2020)” as having an incorrect citation or not accurately reflecting an order filed in that case.
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Fabricated (Case Law)Court noted “Gonzalez v. CoreCivic, Inc., 2020 WL 4037167, at *3 (E.D. Cal. July 17, 2020)” was cited incorrectly or does not match the record in that matter.
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Fabricated (Case Law)Court found the citation “Chavez v. SolarCity Corp., No. 13-cv-01797-JST, *2015 WL 1520065, at 2 (N.D. Cal. Mar. 31, 2015)” to be incorrect or not supporting the explanatory phrase attributed to it.
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
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/1150/Villalovos_v._van_de_pol_USA_3_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).