What was hallucinated

Fabricated: Case Law | Appellant cited City of Henderson v. Bldg. & Constr. Trades Council, but the Court's research indicates this citation is fictional. || Fabricated: Case Law | Appellant cited Blakeney v. State, but the Court's research indicates this citation is fictional. || Misrepresented: Case Law | Appellant cited Certified Fire Prot., Inc. v. Precision Constr., Inc.; the Court found the real case does not support the legal proposition for which it was cited. || Misrepresented: Case Law | Appellant cited Coyote Springs Inv. v. Eighth Judicial Dist. Ct.; the Court found the real case does not support the legal proposition for which it was cited.

Details

Order to Show Cause is here.

Sanction teardown · SC Nevada, USA · 2026-04-22

Yanling Zhang v. Yanhui Zhang

What happened

In SC Nevada, 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)

Appellant cited City of Henderson v. Bldg. & Constr. Trades Council, but the Court's research indicates this citation is fictional.
Fabricated (Case Law)

Appellant cited Blakeney v. State, but the Court's research indicates this citation is fictional.
Misrepresented (Case Law)

Appellant cited Certified Fire Prot., Inc. v. Precision Constr., Inc.; the Court found the real case does not support the legal proposition for which it was cited.
Misrepresented (Case Law)

Appellant cited Coyote Springs Inv. v. Eighth Judicial Dist. Ct.; the Court found the real case does not support the legal proposition for which it was cited.

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

Monetary Fine; Bar Referral; Refusal to file corrected brief (monetary penalty: 250 USD.)

Additional detail

Order to Show Cause is 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/2088/Zhang_v._Zhang_USA_22_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).