What was hallucinated

Fabricated: Case Law | Plaintiffs cited a nonexistent case; the Court could not locate it on Westlaw, Lexis, or the internet and warned that citing nonexistent authority may warrant Rule 11 sanctions.

Details

AI UseThe plaintiff, proceeding pro se, cited “Darling v. Linde, Inc., No. 21-cv-01258, 2023 WL 2320117 (D. Or. Feb. 28, 2023)” in briefing. The court stated it could not locate the case in any major legal database or via internet search and noted this could trigger Rule 11 sanctions if not based on a reasonable inquiry. The ruling cited Saxena v. Martinez-Hernandez as a cautionary example involving AI hallucinations, suggesting the court suspected similar conduct here.

Sanction teardown · W.D. Washington, USA · 2025-05-15

Beenshoof v. Chin

What happened

In W.D. Washington, 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)

Plaintiffs cited a nonexistent case; the Court could not locate it on Westlaw, Lexis, or the internet and warned that citing nonexistent authority may warrant Rule 11 sanctions.

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

No sanction imposed; court reminded Plaintiff of Rule 11 obligations

Additional detail

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/339/Beenshoof_v._Chin_WD_Washington_USA_May_15_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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