What was hallucinated

Fabricated: Case Law | The petition cited a nonexistent California case. The court expressly found that the cited case does not exist. || Fabricated: Case Law | The case exists, but the citation used the wrong first page. The court found that the correct page cite is 1074, not 1030. || Fabricated: Case Law | The petition cited a nonexistent bankruptcy case. The cited reporter reference leads to In re Munoz, and the court also found that the authority did not support the proposition asserted. || Misrepresented: Case Law | The cited case exists, but the petition attributed to it the proposition that a trial court maintains no judicial discretion to enforce a void judgment. The court found that the case did not stand for that proposition and lacked a pinpoint citation.

Sanction teardown · SC California, USA · 2026-08-05

Southland Homes & Real Estate and Investment, LLC v. Lam

What happened

In SC California, USA, a filing relied on ChatGPT and Google Gemini to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

The petition cited a nonexistent California case. The court expressly found that the cited case does not exist.
Fabricated (Case Law)

The case exists, but the citation used the wrong first page. The court found that the correct page cite is 1074, not 1030.
Fabricated (Case Law)

The petition cited a nonexistent bankruptcy case. The cited reporter reference leads to In re Munoz, and the court also found that the authority did not support the proposition asserted.
Misrepresented (Case Law)

The cited case exists, but the petition attributed to it the proposition that a trial court maintains no judicial discretion to enforce a void judgment. The court found that the case did not stand for that proposition and lacked a pinpoint citation.

Which AI tool

ChatGPT and Google Gemini. 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 Sanctions; Bar Referral (monetary penalty: 4000 USD.)

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/3219/Lam_v._Southland_Homes__Real_Estate_and_Investment_LLC_USA_05-08-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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