What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Jorgensen v. CBS, Inc., 728 F.2d 958 (8th Cir. 1984),' which the Court found does not exist and misrepresents the reporter citation (728 F.2d 953 is United States v. Johns (7th Cir. 1984)). Court treated the citation as a fabricated authority. || Fabricated: Case Law | Plaintiff cited 'Lamon v. Godbolt, 2015 WL 13647670 (C.D. Cal. Mar. 30, 2015),' which the Court found to be nonexistent in the Central District and the Westlaw number refers to an unrelated state-court matter; Court treated this as a fabricated/fictitious citation. || Fabricated: Exhibits & Submissions | Unauthorized supplemental brief (Dkt. 64) contained images with nonsensical spellings and text (e.g., 'Twombly/idqal + Three Bays'; 'Comedie Freeze'), which the Court identified as likely generated by AI and therefore fabricated exhibit content.

Sanction teardown · C.D. California, USA · 2026-03-16

Meriland Keith Dillard v. CBS Studios, Inc.

What happened

In C.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:

Fabricated (Case Law)

Plaintiff cited 'Jorgensen v. CBS, Inc., 728 F.2d 958 (8th Cir. 1984),' which the Court found does not exist and misrepresents the reporter citation (728 F.2d 953 is United States v. Johns (7th Cir. 1984)). Court treated the citation as a fabricated authority.
Fabricated (Case Law)

Plaintiff cited 'Lamon v. Godbolt, 2015 WL 13647670 (C.D. Cal. Mar. 30, 2015),' which the Court found to be nonexistent in the Central District and the Westlaw number refers to an unrelated state-court matter; Court treated this as a fabricated/fictitious citation.
Fabricated (Exhibits & Submissions)

Unauthorized supplemental brief (Dkt. 64) contained images with nonsensical spellings and text (e.g., 'Twombly/idqal + Three Bays'; 'Comedie Freeze'), which the Court identified as likely generated by AI and therefore fabricated exhibit content.

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

Factor in dismissing with prejudice

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/1838/Meriland_Keith_Dillard_v._CBS_Studios_Inc._USA_16_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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