What was hallucinated

Fabricated: Case Law | The trial-court order allegedly cited Cummings v. Cimarron Elevator Co., 1998 OK CIV APP 44, 958 P.2d 594, as an Oklahoma Court of Civil Appeals decision adopting Schlagenhauf standards for examinations under 12 O.S. § 3235. The petitioner states that 1998 OK CIV APP 44 is actually Robbins v. Robbins, which concerns alleged ex parte communications in a custody matter, and that 958 P.2d 594 is an Idaho case, Harpole v. State, unrelated to § 3235. || Fabricated: Case Law | The trial-court order allegedly cited Hawkins v. Linhart, 2009 OK CIV APP 106, 234 P.3d 240, as reaffirming that § 3235 is not self-executing and requires an in-controversy and good-cause showing. The petitioner states that 2009 OK CIV APP 106 is actually Bunch v. Terpenning, concerning the Consumer Credit Code, and that 234 P.3d 240 does not correspond to an Oklahoma case; the cited reporter volume instead identifies an unrelated Washington case, Bennett v. Smith Bunday Berman Britton, PS. || Misrepresented: Case Law | The trial-court order allegedly attributed a detailed quotation and legal propositions concerning psychological examinations, emotional-distress claims, and the requirements of § 3235 to the nonexistent Cummings and Hawkins decisions. The petitioner asserts that neither purported case exists and that the actual cases associated with the cited references do not contain or support those propositions.

Details

Allegations first made by Counsel in underlying case (see here). Judge later acknowledged the lapse (see here), and is now under investigation.

Sanction teardown · DC Oklahoma, USA · 2025-11-19

Beason v. Wheeler

What happened

In DC Oklahoma, 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)

The trial-court order allegedly cited Cummings v. Cimarron Elevator Co., 1998 OK CIV APP 44, 958 P.2d 594, as an Oklahoma Court of Civil Appeals decision adopting Schlagenhauf standards for examinations under 12 O.S. § 3235. The petitioner states that 1998 OK CIV APP 44 is actually Robbins v. Robbins, which concerns alleged ex parte communications in a custody matter, and that 958 P.2d 594 is an Idaho case, Harpole v. State, unrelated to § 3235.
Fabricated (Case Law)

The trial-court order allegedly cited Hawkins v. Linhart, 2009 OK CIV APP 106, 234 P.3d 240, as reaffirming that § 3235 is not self-executing and requires an in-controversy and good-cause showing. The petitioner states that 2009 OK CIV APP 106 is actually Bunch v. Terpenning, concerning the Consumer Credit Code, and that 234 P.3d 240 does not correspond to an Oklahoma case; the cited reporter volume instead identifies an unrelated Washington case, Bennett v. Smith Bunday Berman Britton, PS.
Misrepresented (Case Law)

The trial-court order allegedly attributed a detailed quotation and legal propositions concerning psychological examinations, emotional-distress claims, and the requirements of § 3235 to the nonexistent Cummings and Hawkins decisions. The petitioner asserts that neither purported case exists and that the actual cases associated with the cited references do not contain or support those propositions.

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

Judge acknowledged mistake

Additional detail

Allegations first made by Counsel in underlying case (see here). Judge later acknowledged the lapse (see here), and is now under investigation.

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/3055/Wheeler_AI_Fabricated_Citations_Order_Nov_19_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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