“We do not issue that placeholder as a threat to scare anybody into court, even if
  this person heard differently from somebody in our organization,”

Hmmm. It's in the US, so maybe "liability for causing emotional damage" is relevant for this? :)

Software? A human decided to use a place holder value.

The article mentions that "The figure Cato received reflected a “placeholder” that was automatically generated by e-citation software"

Not a typo, interesting