Sanction teardown · S.D. Florida, USA · 2025-11-21
Alexey Dubinin v. Varsenik Papazian
What happened
In S.D. Florida, 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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Fabricated (Case Law)Plaintiff's Response cited a decision from this Court that does not exist; the Court's independent review confirmed non-existence.
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False Quotes (Case Law)Response included quotations attributed to Eleventh Circuit opinions that do not appear in those opinions; Court identified multiple such misquotes.
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Fabricated (Case Law)Court's Order to Show Cause listed at least ten instances across the Complaint and Response citing non-existent cases and quotes (AI-hallucinated authorities).
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
Costs Order; Bar Referral (monetary penalty: 4030 USD.)
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/1066/Dubinin_v._Papazian_USA_21_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).