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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
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In re termination of parental rights (HK)
CA Arizona · Feb 25, 2026
AZ / stateEditorial impact: highfake citationsfabricated quotesbar referralfamily
Direct answer
What happened in this matter?
False Quotes: Case Law | Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion. Outcome: Bar Referral.
- Why the court cared
- False Quotes: Case Law | Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion. || Fabricated: Legal Norm | Mother's brief quoted A.R.S. § 8-531(1) as stating: '[a]bandonment is measured by a parent's conduct, not the parent's subjective intent.' The court found this quoted statutory language does not appear in § 8-531(1). || Fabricated: Legal Norm | Mother's brief attributed language to A.R.S. § 8-533(B)(1) stating abandonment is established when a parent has failed to maintain a normal parental relationship 'without just cause.' The court found the statute does not contain the quoted phrasing. || False Quotes: Case Law | Mother's brief attributed a non-existent quote to Raymond F. v. Dep't of Econ. Sec., 224 Ariz. 373, 378, ¶ 21 (App. 2010): '[a] parent who creates barriers to contact through substance abuse cannot claim just cause for his failure to maintain a relationship.' The court found this quotation does not appear in Raymond F.
- Why it matters now
- Fabricated statutory quotes in termination-of-parental-rights briefs trigger bar referral — require second-attorney verification of every quote.
Why this matter is tracked
False Quotes: Case Law | Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion. Outcome: Bar Referral.
Operational lesson
Fabricated statutory quotes in termination-of-parental-rights briefs trigger bar referral — require second-attorney verification of every quote.
Record details
ArizonaSingle-state evidence scope
CourtCA Arizona
Jurisdictionstate
Circuit9th Circuit
DateFeb 25, 2026
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeBar Referral
Known amountNot recorded
Professional sanctionYes
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Bar Referral
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion.
- Fabricated: Legal Norm | Mother's brief quoted A.R.S. § 8-531(1) as stating: '[a]bandonment is measured by a parent's conduct, not the parent's subjective intent.' The court found this quoted statutory language does not appear in § 8-531(1).
- Fabricated: Legal Norm | Mother's brief attributed language to A.R.S. § 8-533(B)(1) stating abandonment is established when a parent has failed to maintain a normal parental relationship 'without just cause.' The court found the statute does not contain the quoted phrasing.
- False Quotes: Case Law | Mother's brief attributed a non-existent quote to Raymond F. v. Dep't of Econ. Sec., 224 Ariz. 373, 378, ¶ 21 (App. 2010): '[a] parent who creates barriers to contact through substance abuse cannot claim just cause for his failure to maintain a relationship.' The court found this quotation does not appear in Raymond F.
Questions this record answers
- What happened in In re termination of parental rights (HK)?
- False Quotes: Case Law | Mother cited JS-501568, 177 Ariz. at 577, attributing multiple sentences the court could not find, including 'a parent's ability to maintain a relationship must be judged by what they do, not what another parent does or does not do' and 'minimal efforts do not preclude abandonment ... sporadic or infrequent contact is not normal parental contact.' The court concluded these quotes are not in that opinion. Outcome: Bar Referral.
- Why does In re termination of parental rights (HK) matter for legal AI risk?
- Fabricated statutory quotes in termination-of-parental-rights briefs trigger bar referral — require second-attorney verification of every quote.
- What does the public record establish about In re termination of parental rights (HK)?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this In re termination of parental rights (HK) 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.