Sanction teardown · N.D. California, USA · 2025-07-25
Pop Top Corp. v. Rakuten Kobo
What happened
In N.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)Court found that the cited case does not exist; SDNY ECF shows a different matter for the docket number and Westlaw search for the WL citation did not yield the titled case.
-
Fabricated (Case Law)Opposing party flagged and the court confirmed that no Ninth Circuit case by this title or with this citation exists.
-
Fabricated (Case Law)Opposing party flagged and the court confirmed that no W.D. Va. case/order matches this title, WL number, or date.
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
Warning
Additional detail
"Chandra’s self-represented status does not permit him to submit information blindly. Likeevery other person who appears before the court, he has an obligation to confirm that arguments andcase law submitted to the court are supported by existing law, and a failure to do so is sanctionable."
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.govinfo.gov/content/pkg/USCOURTS-cand-4_20-cv-04482/pdf/USCOURTS-cand-4_20-cv-04482-6.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).