Sanction teardown · E.D. Tennessee, USA · 2025-07-29
Axis Dynamics, Inc. v. Knox County, Tennessee
What happened
In E.D. Tennessee, 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 (Legal Norm)Plaintiffs cited Ala. Code § 7-5-116(4); the court found no such subsection exists and that §7-5-116 does not address third-party rights.
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Fabricated (Case Law)Plaintiffs relied on 'Meridian Mut. Ins. Co. v. Huntsville, 141 So. 3d 415 (Ala. 2013)'; the court was unable to locate this opinion and determined the cited authority does not exist.
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Misrepresented (Case Law)Plaintiffs cited Landale Enters. v. Berry, 676 F.2d 506 (11th Cir. 1982) as supporting the defeat of third-party disclaimers; the court found Landale does not address third-party rights disclaimers and does not support Plaintiffs' proposition.
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Misrepresented (Case Law)Plaintiffs relied on Iskra v. Bear Roofing, LLC, 406 So. 3d 51 (Ala. 2024); the court found the case exists but does not involve third-party rights disclaimers or the proposition Plaintiffs advanced.
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Misrepresented (Case Law)Plaintiffs cited Brown v. Gadsden Regional Medical Center, LLC, 748 Fed. App'x 930 (11th Cir. 2018) as supporting a direct-payment-created beneficiary; the court found Brown actually held the opposite given a disclaimer in the contract.
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
Admonishment and 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/2102/Axis_Dynamics_Inc_v_Knox_County_Tennessee_USA_29_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).