What was hallucinated

Misrepresented: Case Law | Plaintiff used an incorrect pinpoint citation to People v. Dang, citing page 1305 though the published opinion ends at page 1300, and relied on Dang for a privilege proposition that is inapplicable; court identified the pin‑cite and inapposite reliance. || Fabricated: Case Law | Plaintiff repeatedly cited a nonexistent case, Boyd v. City of San Diego, 14 Cal.App.4th 954, 959-960 (1993); court found no such published authority and treated it as a fictitious citation. || Misrepresented: Case Law | Plaintiff cited In re Grand Jury Subpoena as a Ninth Circuit decision (In re Grand Jury Subpoena (Under Seal) (9th Cir. 1985) 774 F.2d 624), but the opinion is a Fourth Circuit case; court noted the misattribution. || Misrepresented: Case Law | Plaintiff initially cited State of Nevada v. US Dept. of Energy with incorrect reporter information (151 F.3d 1236, 1242); plaintiff later corrected to Nevada v. United States Dep't of Energy, 133 F.3d 1201 (9th Cir. 1998); court accepted correction. || Misrepresented: Case Law | Plaintiff cited In re County of Los Angeles, 223 F.3d 990 (9th Cir. 2000) as supporting an assertion about federal courts' inherent authority, but the court found no explicit passage in that opinion supporting the claimed proposition. || Misrepresented: Case Law | Plaintiff relied on Larson v. Domestic & Foreign Commerce Corp., 337 U.S. 682 (1949) to support the proposition that courts void or enjoin ultra vires public spending; court found Larson only mentions ultra vires and does not support that spending‑enjoining proposition.

Sanction teardown · E.D. California, USA · 2026-04-14

Shaw v. City of Portola, et al.

What happened

In E.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:

Misrepresented (Case Law)

Plaintiff used an incorrect pinpoint citation to People v. Dang, citing page 1305 though the published opinion ends at page 1300, and relied on Dang for a privilege proposition that is inapplicable; court identified the pin‑cite and inapposite reliance.
Fabricated (Case Law)

Plaintiff repeatedly cited a nonexistent case, Boyd v. City of San Diego, 14 Cal.App.4th 954, 959-960 (1993); court found no such published authority and treated it as a fictitious citation.
Misrepresented (Case Law)

Plaintiff cited In re Grand Jury Subpoena as a Ninth Circuit decision (In re Grand Jury Subpoena (Under Seal) (9th Cir. 1985) 774 F.2d 624), but the opinion is a Fourth Circuit case; court noted the misattribution.
Misrepresented (Case Law)

Plaintiff initially cited State of Nevada v. US Dept. of Energy with incorrect reporter information (151 F.3d 1236, 1242); plaintiff later corrected to Nevada v. United States Dep't of Energy, 133 F.3d 1201 (9th Cir. 1998); court accepted correction.
Misrepresented (Case Law)

Plaintiff cited In re County of Los Angeles, 223 F.3d 990 (9th Cir. 2000) as supporting an assertion about federal courts' inherent authority, but the court found no explicit passage in that opinion supporting the claimed proposition.
Misrepresented (Case Law)

Plaintiff relied on Larson v. Domestic & Foreign Commerce Corp., 337 U.S. 682 (1949) to support the proposition that courts void or enjoin ultra vires public spending; court found Larson only mentions ultra vires and does not support that spending‑enjoining proposition.

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

Order to Show Cause

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/1993/Shaw_v._Portola_USA_15_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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