What was hallucinated

Fabricated: Case Law | Plaintiff cited “In re State Street Bank and Trust Co. ERISA Litig., No. 07-cv-10907, 2009 WL 10260136, at *1 (S.D.N.Y. Apr. 8, 2009)”; court found the Westlaw number and caption did not correspond to a real decision. || Fabricated: Case Law | Plaintiff cited “SEC v. Collins, No. 01-cv-3065, 2002 WL 31109065, at *4 (S.D.N.Y. Sept. 23, 2002)”; court found no decision matching that Westlaw number or caption (noting a different SEC v. Collins & Aikman Corp., 256 F.R.D. 403 (S.D.N.Y. 2009) exists but with different citation).

Sanction teardown · S.D. New York, USA · 2026-08-27

Ashmeade v. Amazon.com Services LLC

What happened

In S.D. New York, 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)

Plaintiff cited “In re State Street Bank and Trust Co. ERISA Litig., No. 07-cv-10907, 2009 WL 10260136, at *1 (S.D.N.Y. Apr. 8, 2009)”; court found the Westlaw number and caption did not correspond to a real decision.
Fabricated (Case Law)

Plaintiff cited “SEC v. Collins, No. 01-cv-3065, 2002 WL 31109065, at *4 (S.D.N.Y. Sept. 23, 2002)”; court found no decision matching that Westlaw number or caption (noting a different SEC v. Collins & Aikman Corp., 256 F.R.D. 403 (S.D.N.Y. 2009) exists but with different citation).

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/2992/Ashmeade_v._Amazon_USA_27_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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