Skip to main content
Citation Safe

Was That Xiong on the other side of your case?

Check their next brief before they file — Opposition Check verifies every citation in a filed brief for $49, no signup. Get Opposition Check →

That Xiong v. Minga Wofford (2)

Court
E.D. California
Jurisdiction
USA
Decided
2026-05-21
AI tool
ChatGPT
Outcome
No Sanctions in circumstances
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Petitioner's brief cited 'G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025)'; Court found the Westlaw citation corresponded to a different real case, indicating a hallucinated citation likely from GenAI. || Fabricated: Case Law | Court previously identified a citation in Petitioner's reply to 'Phan v. Barr, No. 1:19-cv-01451, 2019 WL 7758773 (E.D. Cal. Dec. 20, 2019)' that it could not locate and which appeared to be hallucinated. || Fabricated: Case Law | Court previously identified a citation in Petitioner's reply to 'Flores v. Barr, No. 1:20-cv-00491, 2020 WL 1939565 (E.D. Cal. Apr. 22, 2020)' that it could not locate and which appeared to be hallucinated.

Details

Order to Show Cause is here. The court concluded:"After careful consideration, including the involvement of a law student at the beginning of their legal career and for the reasons stated above, the Court exercises its discretion to discharge the OSC (ECF No. 49) and declines to impose sanctions on Petitioner’s counsel Cummings or law student [XX] for counsel’s failure to fully comply with the Court’s January 13, 2026 order. The Court repeats its admonishment that while AI and generative AI tools can assist counsel and parties, these tools must be used responsibly. They should not be used to verify legal authorityand citations, especially when generative AI tools were used to generate or identify the legal authority and citations being checked."

Sanction teardown · E.D. California, USA · 2026-05-21

That Xiong v. Minga Wofford (2)

What happened

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

  • Fabricated (Case Law)
    Petitioner's brief cited 'G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025)'; Court found the Westlaw citation corresponded to a different real case, indicating a hallucinated citation likely from GenAI.
  • Fabricated (Case Law)
    Court previously identified a citation in Petitioner's reply to 'Phan v. Barr, No. 1:19-cv-01451, 2019 WL 7758773 (E.D. Cal. Dec. 20, 2019)' that it could not locate and which appeared to be hallucinated.
  • Fabricated (Case Law)
    Court previously identified a citation in Petitioner's reply to 'Flores v. Barr, No. 1:20-cv-00491, 2020 WL 1939565 (E.D. Cal. Apr. 22, 2020)' that it could not locate and which appeared to be hallucinated.

Which AI tool

ChatGPT. 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

No Sanctions in circumstances

Additional detail

Order to Show Cause is here. The court concluded:"After careful consideration, including the involvement of a law student at the beginning of their legal career and for the reasons stated above, the Court exercises its discretion to discharge the OSC (ECF No. 49) and declines to impose sanctions on Petitioner’s counsel Cummings or law student [XX] for counsel’s failure to fully comply with the Court’s January 13, 2026 order. The Court repeats its admonishment that while AI and generative AI tools can assist counsel and parties, these tools must be used responsibly. They should not be used to verify legal authorityand citations, especially when generative AI tools were used to generate or identify the legal authority and citations being checked."

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/2187/Xiong_v._Wofford_USA_21_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2187/Xiong_v._Wofford_USA_21_May_2026.pdf

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checkerBack to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49Sanctions-motion template