Sanction teardown · D. New Jersey, USA · 2025-09-25
Alexander Shaporov v. PIPPD P.O. Matthew Levine, et al.
What happened
In D. New Jersey, 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:
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False Quotes (Case Law)Plaintiff attributed a quoted sentence to Camiolo (3d Cir.) that does not appear there; the language instead appeared in Frohner quoting Mounts (7th Cir.).
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Misrepresented (Case Law)Plaintiff quoted language as if from Gilles (3d Cir.), but the passage was a parenthetical quotation of a Seventh Circuit case (Kijonka).
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Fabricated (Case Law)Incorrect case number, Westlaw citation, and decision date for Manitta; Plaintiff's brief listed a non-matching citation.
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Fabricated (Case Law)Piazza citation in brief used a Westlaw cite and pincite that do not exist / are incorrect (wrong Westlaw number and wrong page).
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Fabricated (Case Law)Ianuale citation in brief contained a wrong Westlaw citation and incorrect pincite (non-matching Westlaw number and page).
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Misrepresented (Case Law)Citation to State v. Gandhi was used to support a specific statutory interpretation the case does not address; Gandhi was cited only for a general canon of statutory interpretation.
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
Show Cause Order
Additional detail
The district court independently found numerous inaccurate quotations and citations in Plaintiff's Opposition—misquoted language attributed to binding Third Circuit authority, Westlaw citations and dates that were incorrect or non-existent, and miscited pincites. The court concluded the pattern suggested the brief may have been prepared using generative AI without adequate verification and ordered counsel to show cause under Rule 11 and ethical rules. The court preserved the inaccuracies in the official opinion but removed links to invalid citations.
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.
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Source: https://www.damiencharlotin.com/documents/825/ALEXANDER_SHAPOROV_Plaintiff_v_PIPPD_PO_MATTHEW_LEVINE_et_al_Defendants.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).