What was hallucinated

Misrepresented: Case Law | Cited Terramar Retail Centers for the proposition that the Court has broad discretion in discovery, but Terramar addressed a Rule 12(b)(2) motion and did not support the cited discovery principle. || False Quotes: Case Law | Attributed the quote "A party cannot unilaterally decide to stay discovery." to Deutsch v. ZST Digital Networks, Inc.; the quote is not in Deutsch and the case addressed a receiver's contempt/arrest-warrant matter. || False Quotes: Case Law | Quoted Production Resources Group v. NCT Group as stating "Delaware courts have traditionally construed the scope of permissible discovery liberally," but the quoted language is not found in NCT or other cases searched.

Sanction teardown · Delaware Ch., USA · 2025-04-04

An v. Archblock, Inc.

What happened

In Delaware Ch., 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:

Misrepresented (Case Law)

Cited Terramar Retail Centers for the proposition that the Court has broad discretion in discovery, but Terramar addressed a Rule 12(b)(2) motion and did not support the cited discovery principle.
False Quotes (Case Law)

Attributed the quote "A party cannot unilaterally decide to stay discovery." to Deutsch v. ZST Digital Networks, Inc.; the quote is not in Deutsch and the case addressed a receiver's contempt/arrest-warrant matter.
False Quotes (Case Law)

Quoted Production Resources Group v. NCT Group as stating "Delaware courts have traditionally construed the scope of permissible discovery liberally," but the quoted language is not found in NCT or other cases searched.

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

Warning

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/2361/34_-_An_v_Archblock_Inc.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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