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Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al.

Court
D. Utah
Jurisdiction
USA
Decided
2025-12-04
AI tool
Implied
Outcome
Order for counsel to read cited authorities and file a certification within 30 days
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Opposition cited Rawson v. Mathews, 212 P.3d 752, 756–57 (Utah 2009) to support equitable tolling; court determined the opinion does not exist and called it a hallucinated case. || Fabricated: Case Law | Opposition cited Equilon Enters. v. Ford Motor Co., 2010 UT 44, ¶ 37 for equitable tolling; court found the opinion does not exist and treated it as a fabricated citation. || False Quotes: Case Law | Opposition attributed language to Agency Holding Corp. v. Malley-Duff & Assocs., 483 U.S. 143 (1987) that does not appear in the opinion; court treated this as a false quotation/misattribution.

Sanction teardown · D. Utah, USA · 2025-12-04

Black Oak Capital BOCA, LLC v. Paul Evans, LLC, et al.

What happened

In D. Utah, 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)
    Opposition cited Rawson v. Mathews, 212 P.3d 752, 756–57 (Utah 2009) to support equitable tolling; court determined the opinion does not exist and called it a hallucinated case.
  • Fabricated (Case Law)
    Opposition cited Equilon Enters. v. Ford Motor Co., 2010 UT 44, ¶ 37 for equitable tolling; court found the opinion does not exist and treated it as a fabricated citation.
  • False Quotes (Case Law)
    Opposition attributed language to Agency Holding Corp. v. Malley-Duff & Assocs., 483 U.S. 143 (1987) that does not appear in the opinion; court treated this as a false quotation/misattribution.

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

Order for counsel to read cited authorities and file a certification within 30 days

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/1144/Black_Oak_Capital_v._Paul_Evans_USA_4_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1144/Black_Oak_Capital_v._Paul_Evans_USA_4_December_2025.pdf

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