What was hallucinated

Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., No. 17-MC-80244, 2018 WL 1898913, at *4 (N.D. Cal. Apr. 19, 2018)' to support delayed notice; the court found this cited opinion does not exist. || Fabricated: Case Law | Plaintiff cited 'In re Subpoena to Coinbase, Inc., 2023 WL 177977, at 2 (N.D. Cal. Jan. 12, 2023)'; the court could not locate this citation on Westlaw and noted only an unrelated CourtListener docket for 'In re: Coinbase, Inc.' (23-1779). || Misrepresented: Case Law | Plaintiff relied on Strike 3 Holdings, LLC v. Doe, 964 F.3d 1203 (D.C. Cir. 2020) as approving 'delayed notice' to prevent targets from knowing of subpoenas; the court observed Strike 3 contains no discussion of preventing a subpoena target from learning of the subpoena and therefore does not support plaintiff's proposition. || Misrepresented: Case Law | Plaintiff cited Hard Drive Productions, Inc., 809 F. Supp. 2d 1150 (N.D. Cal. 2011) as supporting nondisclosure/delayed notice; the court found Hard Drive authorized notice to subscribers (the opposite of delayed notice) and does not support plaintiff's position. || Misrepresented: Case Law | Plaintiff cited Arista Records LLC v. Does 1-27, 584 F. Supp. 2d 240, 254 (D.D.C. 2008) to argue courts approved email service for early discovery; the court noted Arista is a decision from the District of Maine (584 F. Supp. 2d 240 (D. Me. 2008)) and did not address Rule 45 email service, so the citation was both jurisdictionally and substantively mischaracterized.

Sanction teardown · D. Colorado, USA · 2025-11-19

Y.S. v. John Doe et al.

What happened

In D. Colorado, 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)

Plaintiff cited 'In re Subpoena to Coinbase, Inc., No. 17-MC-80244, 2018 WL 1898913, at *4 (N.D. Cal. Apr. 19, 2018)' to support delayed notice; the court found this cited opinion does not exist.
Fabricated (Case Law)

Plaintiff cited 'In re Subpoena to Coinbase, Inc., 2023 WL 177977, at 2 (N.D. Cal. Jan. 12, 2023)'; the court could not locate this citation on Westlaw and noted only an unrelated CourtListener docket for 'In re: Coinbase, Inc.' (23-1779).
Misrepresented (Case Law)

Plaintiff relied on Strike 3 Holdings, LLC v. Doe, 964 F.3d 1203 (D.C. Cir. 2020) as approving 'delayed notice' to prevent targets from knowing of subpoenas; the court observed Strike 3 contains no discussion of preventing a subpoena target from learning of the subpoena and therefore does not support plaintiff's proposition.
Misrepresented (Case Law)

Plaintiff cited Hard Drive Productions, Inc., 809 F. Supp. 2d 1150 (N.D. Cal. 2011) as supporting nondisclosure/delayed notice; the court found Hard Drive authorized notice to subscribers (the opposite of delayed notice) and does not support plaintiff's position.
Misrepresented (Case Law)

Plaintiff cited Arista Records LLC v. Does 1-27, 584 F. Supp. 2d 240, 254 (D.D.C. 2008) to argue courts approved email service for early discovery; the court noted Arista is a decision from the District of Maine (584 F. Supp. 2d 240 (D. Me. 2008)) and did not address Rule 45 email service, so the citation was both jurisdictionally and substantively mischaracterized.

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/1068/YS_v._John_Doe_USA_19_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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