Sanction teardown · 11th Cir. CA, USA · 2026-07-10

Akerlund v. Atlas Air, Inc., et al.

What happened

In 11th Cir. CA, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

• Fabricated (Case Law)
  Counsel cited this case as authority; the court found the citation to be a nonexistent, hallucinated case.
• Fabricated (Case Law)
  Counsel cited this district-court opinion; the court determined it was a hallucinated citation.
• Fabricated (Case Law)
  Counsel cited this case as authority; the court found the citation to be a nonexistent, hallucinated case.
• Fabricated (Case Law)
  Counsel cited this purported Middle District of Florida opinion; the court found it did not exist.
• Fabricated (Case Law)
  Counsel cited this alleged Eleventh Circuit or other appellate opinion; the court determined it was fabricated.
• Fabricated (Case Law)
  Counsel cited this Florida appellate opinion (appeared in multiple filings with inconsistent attribution); the court found the citation was hallucinated.
• Fabricated (Case Law)
  Counsel cited this purported Florida Fourth DCA opinion in a reply; the court found it was fabricated.
• Fabricated (Case Law)
  Counsel cited this district-court opinion (D. Colo.); the court concluded the citation was a hallucination.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Bar Referral

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/2592/Akerlund_et_al._v._Altas_Air_Inc._USA_10_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).