Sanction teardown · 9th Cir. CA, USA · 2026-06-03

Lnu v. Blanche

What happened

In 9th Cir. CA, 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)
  Opening brief cited a case that does not exist.
• Fabricated (Case Law)
  Opening brief cited a case that does not exist.
• False Quotes (Case Law)
  Quotation attributed to Kamalthas does not appear in that opinion.
• False Quotes (Case Law)
  Quotation attributed to Avendano-Hernandez does not appear in that opinion.
• Misrepresented (Case Law)
  Real cases were represented as supporting propositions they do not discuss (mischaracterization of holdings).
• Misrepresented (Case Law)
  Real case cited for a point about affidavits when the opinion does not discuss affidavits.
• Fabricated (Case Law)
  Additional fabricated citations identified in other briefs filed by the same attorney.
• Fabricated (Case Law)
  Fabricated citations identified in another matter filed by the same attorney.
• Fabricated (Case Law)
  Opening brief cited a case that does not exist; Court found the citation fabricated and replacement citation (Udo) did not support the claimed proposition.
• Fabricated (Case Law)
  Opening brief cited a second case that does not exist; Court found no plausible typographical explanation and replacement citation (Lai) did not support the original point.
• False Quotes (Case Law)
  Quotation attributed to Kamalthas appears in the brief but the quoted language does not appear in Kamalthas; Court treated this as a false quotation.
• False Quotes (Case Law)
  Quotation attributed to Avendano-Hernandez does not appear in that opinion; Court flagged as misattributed quotation.
• Misrepresented (Case Law)
  Court found that Singh was cited for propositions about adverse credibility and translation errors although the opinion concerns timeliness/equitable tolling; characterized as gross misrepresentation of a real case.
• Fabricated (Case Law)
  Court identified multiple additional fabricated citations in other briefs filed by the same attorney (examples listed) and treated these as further fabricated authorities.

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; 6-month Suspension; Notification Requirement; Bar Suspension (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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/2259/Lnu_v._Blanche_USA_3_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).