Sanction teardown · CA Washington, USA · 2026-06-15
Matthew Merz v. Harlyn Jenkins, Jillane Baros, Melinda Finn‑Kamerath
What happened
In CA Washington, 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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False Quotes (Case Law)Appellant attributed a nonexistent quotation to State ex rel. McCool and presented it as authority.
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False Quotes (Case Law)Appellant incorrectly cites and quotes Olson, misrepresenting that authority.
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Misrepresented (Case Law)Appellant cited Burnet v. Spokane Ambulance but relied on it improperly; court found Burnet concerns CR 37(b) and is inapplicable to the asserted point.
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
Sanctions affirmed
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/2454/Merz_v._Jenkins_USA_15_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).