Sanction teardown · W.D. Washington, USA · 2026-02-09
Valve Corporation v. Rothschild et al.
What happened
In W.D. Washington, 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:
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Outdated Advice (Overturned Case Law)Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling.
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Fabricated (Case Law)Defendants cited a non-existent PacTool opinion and quoted text that does not exist in the case; plaintiff's counsel states the opinion does not exist and the quoted text is fabricated.
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False Quotes (Case Law)Defendants quoted language attributed to Crow Tribe that is not contained in the opinion; plaintiff notes the case exists but the quoted text is fabricated.
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False Quotes (Case Law)Defendants attributed a quotation to Cordis (Fed. Cir.) that does not appear in the opinion; plaintiff identifies the quote as fabricated.
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False Quotes (Case Law)Defendants quoted Bilzerian for language about expert testimony creating an "aura of authority"—plaintiff states the quoted text does not appear in Bilzerian and the proposition is unsupported by that case.
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False Quotes (Case Law)Defendants partially misquoted Primiano; plaintiff notes the quoted language is incorrect and provides the correct formulation from the case.
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False Quotes (Case Law)Defendants attribute an “ipse dixit” quote to Micro Chem. plaintiff says the case exists but the quoted language is not found and the case does not support Defendants' broader proposition.
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Fabricated (Case Law)Defendants cited an Amazon.com v. Personal Web Technologies opinion that plaintiff reports does not exist in the W.D. Wash.; plaintiff identifies the opinion as fabricated.
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Fabricated (Case Law)Defendants cited Diamondback Industries v. Repeat Precision opinion and quoted a holding that plaintiff reports does not exist; plaintiff identifies the opinion/quotation as fabricated.
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Misrepresented (Case Law)Defendants cited Marx & Co. but relied on a proposition the case does not address; plaintiff notes the case exists but was misapplied.
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Misrepresented (Case Law)Defendants cited Bausch & Lomb but attributed a proposition about expert testimony admissibility that the case does not support; plaintiff characterizes this as a misrepresentation.
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False Quotes (Case Law)Defendants cited Fortune Dynamic with a quoted passage not found in the opinion; plaintiff notes the case exists but the specific quoted language was not located in the decision.
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
Order to show cause
Additional detail
When warned about the issue, cousel apologised in an open letter to the Court.Later on, the Court issued a Show Cause Order (see here).
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/1571/Valve_Corporation_v_Rothschild.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).