What was hallucinated

Fabricated: Case Law | Attributed 'In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015)' as authority in Plaintiff's Opposition to Ogilvie's MSJ (p.17); Court found the case fabricated and the reporter/pincite corresponds to an unrelated real case. || Fabricated: Case Law | Same fabricated citation used twice in Plaintiff's Opposition to Transdev's MSJ (Opp'n TMSJ pp.15–16); Court noted counsel failed to disclose these additional uses in initial declaration. || Fabricated: Case Law | Third instance of the same fabricated authority appearing in briefing; Court treated repeated uses as aggravating factor in finding bad faith and imposing monetary and reporting sanctions.

Sanction teardown · C.D. California, USA · 2026-04-28

Tekoma Chaney v. Transdev Services Inc. et al.

What happened

In C.D. California, USA, a filing relied on LexisNexis+ (Protégé) to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Attributed 'In re Shubert, 799 F.3d 1124, 1129 (9th Cir. 2015)' as authority in Plaintiff's Opposition to Ogilvie's MSJ (p.17); Court found the case fabricated and the reporter/pincite corresponds to an unrelated real case.
Fabricated (Case Law)

Same fabricated citation used twice in Plaintiff's Opposition to Transdev's MSJ (Opp'n TMSJ pp.15–16); Court noted counsel failed to disclose these additional uses in initial declaration.
Fabricated (Case Law)

Third instance of the same fabricated authority appearing in briefing; Court treated repeated uses as aggravating factor in finding bad faith and imposing monetary and reporting sanctions.

Which AI tool

LexisNexis+ (Protégé). 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; Reporting to other courts (monetary penalty: 2500 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/2041/Chaney_v._Transdev_Services_USA_28_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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