What was hallucinated

Fabricated: Case Law | Motion to remand relied on a fabricated case; the Court flagged it as a significant error and part of the Rule 11 violation. || False Quotes: Exhibits & Submissions | Motion used fabricated quotations purportedly from the complaint (nonexistent pleading allegations), which the Court treated as a Rule 11 breach.

Details

AI UsePlaintiff’s counsel admitted using generative AI to draft a motion to remand without independently verifying the legal citations or the factual accuracy of quoted complaint allegations.Hallucination DetailsCited a fabricated case (details of the specific case name not listed in the ruling). Included fabricated quotations from the complaint, suggesting nonexistent factual allegations.Ruling/SanctionThe Court imposed a $2,500 sanction payable by December 30, 2024. Counsel was also required to notify the California State Bar of the sanction and file proof of notification and payment. The Court recognized mitigating factors (health issues, post-hoc corrective measures) but stressed the seriousness of the violations.Key Judicial ReasoningRule 11 requires attorneys to conduct a reasonable inquiry into both facts and law. Use of AI does not diminish this duty. Subjective good faith is irrelevant: violations occur even without intent to deceive. AI-generated filings must be reviewed with the same rigor as traditional submissions.

Sanction teardown · C.D. California, USA · 2024-10-30

Mortazavi v. Booz Allen Hamilton, 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)

Motion to remand relied on a fabricated case; the Court flagged it as a significant error and part of the Rule 11 violation.
False Quotes (Exhibits & Submissions)

Motion used fabricated quotations purportedly from the complaint (nonexistent pleading allegations), which the Court treated as a Rule 11 breach.

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

$2,500 Monetary Sanction + Mandatory Disclosure to California State Bar

Additional detail

AI UsePlaintiff’s counsel admitted using generative AI to draft a motion to remand without independently verifying the legal citations or the factual accuracy of quoted complaint allegations.Hallucination DetailsCited a fabricated case (details of the specific case name not listed in the ruling). Included fabricated quotations from the complaint, suggesting nonexistent factual allegations.Ruling/SanctionThe Court imposed a $2,500 sanction payable by December 30, 2024. Counsel was also required to notify the California State Bar of the sanction and file proof of notification and payment. The Court recognized mitigating factors (health issues, post-hoc corrective measures) but stressed the seriousness of the violations.Key Judicial ReasoningRule 11 requires attorneys to conduct a reasonable inquiry into both facts and law. Use of AI does not diminish this duty. Subjective good faith is irrelevant: violations occur even without intent to deceive. AI-generated filings must be reviewed with the same rigor as traditional submissions.

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/245/Mortazavi_v._Booz_Allen_Hamilton_US_DC_Central_California_October_30_2024.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).