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Preston House v. TH Foods, Inc.

Court
D. Nevada
Jurisdiction
USA
Decided
2026-06-18
AI tool
Implied
Outcome
Briefs struck; Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff cited a case the court identified as apparently hallucinated; the court noted Scherer v. UTI Worldwide, Inc., 2017 WL 2806896 (D. Nev. 2017) appears fabricated. || False Quotes: Case Law | Plaintiff attributed specific Rule 35-related quotations to Schlagenhauf; the court found the quoted passages are not in that decision. || Fabricated: Case Law | Plaintiff cited a case the court identified as apparently hallucinated; the court noted EEOC v. Kaiser Found. Hosp., 2006 WL 3293362 (N.D. Cal. 2006) appears fabricated. || False Quotes: Case Law | Plaintiff quoted a passage and attributed it to Henry v. Gill Inds., Inc.; the court found the quoted language does not appear in that opinion. || False Quotes: Case Law | Plaintiff quoted a passage and attributed it to Zivkovic v. Southern California Edison Co.; the court found the quoted language does not appear in that opinion. || False Quotes: Case Law | Plaintiff attributed the line "At some point, litigation must come to an end" to Cornwell; the court found the quotation does not appear in that case. || False Quotes: Case Law | Plaintiff attributed a limiting-discovery quotation to Rivera v. NIBCO, Inc.; the court found the quoted language is not in Rivera. || False Quotes: Case Law | Plaintiff attributed a broad authority-to-limit-discovery quotation to Hallett v. Morgan; the court found the quotation does not appear in that opinion. || False Quotes: Case Law | Plaintiff cited Gattegno for a proposition about Rule 37(b) that the court found the case does not stand for or discuss.

Sanction teardown · D. Nevada, USA · 2026-06-18

Preston House v. TH Foods, Inc.

What happened

In D. Nevada, 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 a case the court identified as apparently hallucinated; the court noted Scherer v. UTI Worldwide, Inc., 2017 WL 2806896 (D. Nev. 2017) appears fabricated.
  • False Quotes (Case Law)
    Plaintiff attributed specific Rule 35-related quotations to Schlagenhauf; the court found the quoted passages are not in that decision.
  • Fabricated (Case Law)
    Plaintiff cited a case the court identified as apparently hallucinated; the court noted EEOC v. Kaiser Found. Hosp., 2006 WL 3293362 (N.D. Cal. 2006) appears fabricated.
  • False Quotes (Case Law)
    Plaintiff quoted a passage and attributed it to Henry v. Gill Inds., Inc.; the court found the quoted language does not appear in that opinion.
  • False Quotes (Case Law)
    Plaintiff quoted a passage and attributed it to Zivkovic v. Southern California Edison Co.; the court found the quoted language does not appear in that opinion.
  • False Quotes (Case Law)
    Plaintiff attributed the line "At some point, litigation must come to an end" to Cornwell; the court found the quotation does not appear in that case.
  • False Quotes (Case Law)
    Plaintiff attributed a limiting-discovery quotation to Rivera v. NIBCO, Inc.; the court found the quoted language is not in Rivera.
  • False Quotes (Case Law)
    Plaintiff attributed a broad authority-to-limit-discovery quotation to Hallett v. Morgan; the court found the quotation does not appear in that opinion.
  • False Quotes (Case Law)
    Plaintiff cited Gattegno for a proposition about Rule 37(b) that the court found the case does not stand for or discuss.

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

Briefs struck; Warning

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.

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Source: https://www.damiencharlotin.com/documents/2452/Preston_House_v._TH_Foods_USA_18_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2452/Preston_House_v._TH_Foods_USA_18_June_2026.pdf

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