Sanction teardown · E.D. Michigan, USA · 2025-09-19

Ali v. IT People Corporation

What happened

In E.D. Michigan, 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:

• False Quotes (Case Law)
  Plaintiff falsely represented that Union Planters v. L&J Dev. Co., 115 F.3d 378 (6th Cir. 1997) contained language holding that Rule 11 sanctions are “reserved for exceptional circumstances”; court found this a false quotation and pivotal misrepresentation.
• Misrepresented (Legal Norm)
  Plaintiff falsely stated that Michigan's Bullard-Plawecki Employee Right to Know Act requires employers to produce personnel records within 10 business days; court found this statutory deadline claim to be a misrepresentation of the law.
• Fabricated (Legal Norm)
  Plaintiff cited Michigan Admin. Code R 408.8004, a regulatory provision that the court determined does not exist (a phantom or fabricated regulatory citation); plaintiff admitted the citation was nonexistent.

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

Monetary Sanction (monetary penalty: 600 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.

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

Source: https://www.damiencharlotin.com/documents/811/Ali_v._People_Corporation.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).