What was hallucinated

Fabricated: Case Law | Appellant cited Goldstine v. LibertyMut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020), which the court identified as a fabricated (nonexistent) case created by AI. || False Quotes: Case Law | Appellant attributed a quotation to Schimmel v. Levin (195 Cal.App.4th 81) that does not appear in that opinion; court found the quoted language fabricated. || False Quotes: Case Law | Appellant quoted language attributed to Regency Health Services, Inc. v. Superior Court (64 Cal.App.4th 1496) that does not appear in the opinion; the court concluded the quotation was fabricated. || Misrepresented: Case Law | Appellant cited Peake v. Underwood (227 Cal.App.4th 428) as supporting sanctions for filing a second dispositive motion, but the court does not address that issue; the citation was misused/false. || False Quotes: Case Law | Appellant attributed words and a sanctions principle to Heckert v. MacDonald (208 Cal.App.3d 832) that do not appear in that opinion; the court found the quotation inaccurate.

Details

"In total, appellant's opening brief contains 23 case quotations, 21 of which are fabrications. Appellant's reply brief contains many more fabricated quotations. And, both briefs are peppered with inaccurate citations that do not support the propositions for which they are cited.[...]We conclude by noting that "hallucination" is a particularly apt word to describe the darker consequences of AI. AI hallucinates facts and law to an attorney, who takes them as real and repeats them to a court. This court detected (and rejected) these particular hallucinations. But there are many instances-hopefully not in a judicial setting-where hallucinations are circulated, believed, and become "fact" and "law" in some minds. We all must guard against those instances."

Sanction teardown · CA California, USA · 2025-09-12

Noland v. Land

What happened

In CA 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)

Appellant cited Goldstine v. LibertyMut. Ins. Co., 2020 WL 6216738 (W.D. Wash. 2020), which the court identified as a fabricated (nonexistent) case created by AI.
False Quotes (Case Law)

Appellant attributed a quotation to Schimmel v. Levin (195 Cal.App.4th 81) that does not appear in that opinion; court found the quoted language fabricated.
False Quotes (Case Law)

Appellant quoted language attributed to Regency Health Services, Inc. v. Superior Court (64 Cal.App.4th 1496) that does not appear in the opinion; the court concluded the quotation was fabricated.
Misrepresented (Case Law)

Appellant cited Peake v. Underwood (227 Cal.App.4th 428) as supporting sanctions for filing a second dispositive motion, but the court does not address that issue; the citation was misused/false.
False Quotes (Case Law)

Appellant attributed words and a sanctions principle to Heckert v. MacDonald (208 Cal.App.3d 832) that do not appear in that opinion; the court found the quotation inaccurate.

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; State Bar notified; opinion to be served on client. (monetary penalty: 10000 USD.)

Additional detail

"In total, appellant's opening brief contains 23 case quotations, 21 of which are fabrications. Appellant's reply brief contains many more fabricated quotations. And, both briefs are peppered with inaccurate citations that do not support the propositions for which they are cited.[...]We conclude by noting that "hallucination" is a particularly apt word to describe the darker consequences of AI. AI hallucinates facts and law to an attorney, who takes them as real and repeats them to a court. This court detected (and rejected) these particular hallucinations. But there are many instances-hopefully not in a judicial setting-where hallucinations are circulated, believed, and become "fact" and "law" in some minds. We all must guard against those instances."

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/778/Noland_v._Land__2025_Cal._App._LEXIS_584.PDF, via Damien Charlotin's public AI Hallucination Cases Database (CC0).