Large language models often hallucinate with high confidence on "random facts" that lack inferable patterns. We formalize the memorization of such facts as a membership testing problem, unifying the discrete error metrics of Bloom filters with the continuous log-loss of LLMs. By analyzing this problem in the regime where facts are sparse in the universe of plausible claims, we establish a rate-distortion theorem: the optimal memory efficiency is characterized by the minimum KL divergence between score distributions on facts and non-facts. This theoretical framework provides a distinctive explanation for hallucination under an idealized setting: even with optimal training, perfect data, and a simplified ``closed world'' setting, the information-theoretically optimal strategy under limited capacity is not to abstain or forget, but to assign high confidence to some non-facts, resulting in hallucination. We validate this theory empirically on both synthetic and real-world data, showing that hallucinations persist as a natural consequence of lossy compression. The same theorem recovers and sharpens classical space lower bounds for Bloom-type filters, pinning down an additive constant left open for two-sided filters.