What was hallucinated

Fabricated: Case Law | Patterson cited a non-existent federal case to support her arguments; court flagged it as fabricated authority. || Misrepresented: Case Law | Patterson cited Romero for a proposition about the Uniform Commercial Code though Romero is a criminal case and does not support the proposition (misapplied precedent). || Fabricated: Case Law | Patterson relied on a purported Fifth Circuit decision that the court determined does not exist. || Fabricated: Case Law | Multiple cited bankruptcy decisions listed in the brief were identified as nonexistent or unverifiable AI-generated citations. || False Quotes: Case Law | A quotation was attributed to a real California Supreme Court decision but the quoted language does not appear in that decision (false quotation).

Sanction teardown · CA California (4d), USA · 2026-06-23

Trina R. Patterson v. Digital Federal Credit Union

What happened

In CA California (4d), 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:

Fabricated (Case Law)

Patterson cited a non-existent federal case to support her arguments; court flagged it as fabricated authority.
Misrepresented (Case Law)

Patterson cited Romero for a proposition about the Uniform Commercial Code though Romero is a criminal case and does not support the proposition (misapplied precedent).
Fabricated (Case Law)

Patterson relied on a purported Fifth Circuit decision that the court determined does not exist.
Fabricated (Case Law)

Multiple cited bankruptcy decisions listed in the brief were identified as nonexistent or unverifiable AI-generated citations.
False Quotes (Case Law)

A quotation was attributed to a real California Supreme Court decision but the quoted language does not appear in that decision (false quotation).

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

Warning

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/2472/Patterson_v._Digital_Federal_Credit_Union_USA_23_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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