In re termination of parental rights (HK)
CA Arizona · Feb 25, 2026
- Jurisdiction
- state
- Court
- CA Arizona
- Record ID
- in-re-termination-of-parental-rights-hk-2026-02-25
- Observed outcome
- The court affirmed the termination of parental rights and referred Mother's counsel to the State Bar of Arizona for investigation.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Arizona Court of Appeals referred Mother's counsel to the State Bar of Arizona for investigation after counsel included multiple fabricated statutory and case law quotations in an answering brief. The court determined these citations did not exist in the referenced authorities and cited ethical duties of candor.
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.
Fabricated statutory quotes in termination-of-parental-rights briefs trigger bar referral — require second-attorney verification of every quote.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Bar Referral
- Family
- Appellate
- Professional
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a juvenile court's order terminating parental rights, resulting in an affirmance and a referral of counsel to the State Bar.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Train lawyers and staff to identify and verify generated legal content.
- Assign a responsible reviewer for AI-assisted research and drafting.