What was hallucinated

False Quotes: Case Law | Counsel admitted that a quotation attributed to Stevens did not appear in the opinion and withdrew it after the Court identified the error. || False Quotes: Case Law | Counsel admitted that a quotation attributed to Harris did not appear in the opinion and withdrew it after the Court identified the error. || False Quotes: Case Law | Counsel admitted that a quotation attributed to Buxbom did not appear in the opinion and withdrew it after the Court identified the error. || False Quotes: Case Law | Counsel admitted that a quotation attributed to Scott did not appear in the opinion and withdrew it after the Court identified the error. || False Quotes: Case Law | Counsel admitted that a quotation attributed to Miklosy did not appear in the opinion and withdrew it after the Court identified the error. || False Quotes: Case Law | Counsel admitted that a quotation attributed to Hager did not appear in the opinion; opposing counsel had previously identified the problem, and counsel withdrew the quotation and related arguments. || Misrepresented: Case Law | Counsel disclosed that the reply brief relied on citations and characterizations that the cited opinion did not support. || Misrepresented: Case Law | Counsel disclosed and disavowed unsupported citations and characterizations involving Hager in the reply brief beyond the quotation already identified by the Court. || Misrepresented: Case Law | Counsel disclosed that the reply brief relied on citations and characterizations that the cited opinion did not support. || Misrepresented: Case Law | Counsel disclosed that the reply brief relied on citations and characterizations that the cited opinion did not support.

Sanction teardown · CA California (4d), USA · 2026-07-14

Thompson v. County of San Diego

What happened

In CA California (4d), USA, a filing relied on Lexis+ with Protégé to help draft legal argument. The court identified the following problems with the citations in that filing:

False Quotes (Case Law)

Counsel admitted that a quotation attributed to Stevens did not appear in the opinion and withdrew it after the Court identified the error.
False Quotes (Case Law)

Counsel admitted that a quotation attributed to Harris did not appear in the opinion and withdrew it after the Court identified the error.
False Quotes (Case Law)

Counsel admitted that a quotation attributed to Buxbom did not appear in the opinion and withdrew it after the Court identified the error.
False Quotes (Case Law)

Counsel admitted that a quotation attributed to Scott did not appear in the opinion and withdrew it after the Court identified the error.
False Quotes (Case Law)

Counsel admitted that a quotation attributed to Miklosy did not appear in the opinion and withdrew it after the Court identified the error.
False Quotes (Case Law)

Counsel admitted that a quotation attributed to Hager did not appear in the opinion; opposing counsel had previously identified the problem, and counsel withdrew the quotation and related arguments.
Misrepresented (Case Law)

Counsel disclosed that the reply brief relied on citations and characterizations that the cited opinion did not support.
Misrepresented (Case Law)

Counsel disclosed and disavowed unsupported citations and characterizations involving Hager in the reply brief beyond the quotation already identified by the Court.
Misrepresented (Case Law)

Counsel disclosed that the reply brief relied on citations and characterizations that the cited opinion did not support.
Misrepresented (Case Law)

Counsel disclosed that the reply brief relied on citations and characterizations that the cited opinion did not support.

Which AI tool

Lexis+ with 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

Counsel withdrew the unsupported quotations and citations

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/3200/Thompson_v._County_of_San_Diego_USA_14-07-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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