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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 91/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Hocog v. Cook-Huynh
Superior Court of Guam · Aug 11, 2025
GU / stateEditorial impact: lowfake citationsfabricated quotesmisrepresented authoritytort
Direct answer
What happened in this matter?
In Hocog v. Cook-Huynh, the Superior Court of Guam dismissed a medical-malpractice claim against Dr. Mariana Cook-Huynh because the plaintiffs had not properly served the mandatory arbitration demand before the limitations period expired. The court separately examined the plaintiffs’ opposition brief and found numerous citation failures by their attorney: incorrect statutory references, quotations absent from the cited opinions, misstatements of statutes or holdings, a citation to a case that did not exist, and reliance on a California decision that had been vacated without disclosing that fact.…
- Why the court cared
- Strict compliance with the medical-malpractice arbitration service requirement controlled the dismissal; the court then documented counsel’s independent citation failures and stated that further measures would be considered separately.
- Why it matters now
- The court connected source-verification failures to competence and diligence duties, even though the merits dismissal rested on service and limitations grounds.
Why this matter is tracked
In Hocog v. Cook-Huynh, the Superior Court of Guam dismissed a medical-malpractice claim against Dr. Mariana Cook-Huynh because the plaintiffs had not properly served the mandatory arbitration demand before the limitations period expired. The court separately examined the plaintiffs’ opposition brief and found numerous citation failures by their attorney: incorrect statutory references, quotations absent from the cited opinions, misstatements of statutes or holdings, a citation to a case that did not exist, and reliance on a California decision that had been vacated without disclosing that fact. The court counted at least three incorrect statutes or cases, six nonexistent quotations, three misstated authorities, and one nonexistent case. It concluded that the errors violated counsel’s ethical responsibilities and wasted court and client resources, while reserving further review of the misconduct for a separate order or proceeding.
Operational lesson
Before filing briefs citing statutes or slip opinions, require a clerk to pull every citation from the primary source.
Record details
Jurisdiction contextThe state marker is derived from the structured case record.
CourtSuperior Court of Guam
Jurisdictionstate
Circuit9th Circuit
DateAug 11, 2025
IM
AI toolimplied
Party typeLawyer
OutcomePending
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
implied is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Pending
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
8 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Legal Norm | Plaintiffs cited 7 GCA §10105, which does not exist (likely intended 10 GCA §10105).
- Fabricated: Legal Norm | Plaintiffs cited 7 GCA §11038(3), which does not exist.
- False Quotes: Case Law | Provided quotations attributed to Brown v. Dillard IV, Inc. (430 F.3d 1004 (9th Cir. 2005)) that the court found do not appear in the opinion.
- False Quotes: Case Law | Quoted language purportedly from Westcon Construction Corp. v. County of Sacramento (152 Cal. App. 4th 183 (2007)) that the court could not locate in that opinion.
- Outdated Advice: Overturned Case Law | Cited Diaz v. Bukey (195 Cal. App. 4th 315 (2001)) for a proposition without noting the opinion was later vacated by the California Supreme Court; the brief also included an unrelated citation (262 P.3d 1007).
- Misrepresented: Case Law | Cited Penthouse Int'l, Ltd. v. Playboy Enters., Inc. (663 F.2d 371 (2d Cir. 1981)) for an estoppel/apparent authority principle that the court found is not discussed in that opinion.
- Misrepresented: Case Law | Referenced 'In re Application of Santos, 2001 Guam 1' but the court explained 2001 Guam 1 is a different criminal case (People v. Chargualaf), indicating a misidentification/mischaracterization.
- Misrepresented: Case Law | Cited 'Lin SHR Construction Co. v. Acetown, Inc., 2023 Guam 18' as a Guam Supreme Court authority though it is a Superior Court matter and 2023 Guam 18 corresponds to an unrelated criminal citation (People v. Aidan).
Questions this record answers
- What happened in Hocog v. Cook-Huynh?
- In Hocog v. Cook-Huynh, the Superior Court of Guam dismissed a medical-malpractice claim against Dr. Mariana Cook-Huynh because the plaintiffs had not properly served the mandatory arbitration demand before the limitations period expired. The court separately examined the plaintiffs’ opposition brief and found numerous citation failures by their attorney: incorrect statutory references, quotations absent from the cited opinions, misstatements of statutes or holdings, a citation to a case that did not exist, and reliance on a California decision that had been vacated without disclosing that fact.…
- Why does Hocog v. Cook-Huynh matter for legal AI risk?
- The court connected source-verification failures to competence and diligence duties, even though the merits dismissal rested on service and limitations grounds.
- What does the public record establish about Hocog v. Cook-Huynh?
- English-language Guam trial-court order. It documents the inaccuracies but does not identify a specific AI tool or impose the later professional-conduct measure in this order.
- Which source supports this Hocog v. Cook-Huynh summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.