The case was real. The quote inside it was not.
A citation checker that only confirms a case exists will pass this brief without comment. The Ninth Circuit's sanctions order, issued in February 2026, found something harder to spot than a missing case: real, correctly identified opinions with sentences in quotation marks that those opinions never contain.
Existence and support are two different questions. A citation can pass the first and fail the second.
The reassuring citation
Picture a brief that cites a real appellate decision, gives the right court and the right volume, and places a sentence in quotation marks right after it. A reader who checks that the case exists will feel satisfied and move on. The quotation marks are doing work the case itself never did.
This is the subtler half of the citation problem, and it is the one that separates a lookup tool from something that actually reads the source. The Ninth Circuit named the pattern directly: nonexistent cases in one set of findings, and quotations attributed to real opinions that do not contain the quoted words, in another.
What the check has to do differently
A quoted sentence and the case it hangs on are two separate claims traveling together, and Merlise checks them one at a time. First: is the case real? Then: do the exact words, not a paraphrase, actually sit inside that opinion? When they do not, the verdict reads "real authority, quotation not supported" rather than "fabricated citation," a distinct finding with a distinct fix. Pull the quote, or replace it with something the case actually says.
That distinction shapes trust. A tool that treats a misquoted real case the same way it treats a fake one will feel careless to any lawyer who reads the output, because the two problems are not the same size and do not call for the same response.
The evidence ledger
The same claim by claim view the product shows on a live document, built from this case.
How it resolves
The resolving record
The Ninth Circuit's sanctions order names the attorneys, identifies the nonexistent citations separately from the misquoted real ones, and imposes fines alongside a suspension from practice before the court.
Ninth Circuit sanctions order, February 2026
Twenty five hundred dollars in sanctions per attorney and a six month suspension from the court's bar.