What was hallucinated

Fabricated: Case Law | Defendants reported Brown’s brief cited five nonexistent cases; the Court cautioned him about Rule 11. || Misrepresented: Case Law | Brown claimed Hadnot v. Bay 'cited approvingly' Shankle and recognized cost-splitting/confidentiality/discovery limits as unconscionable; the Court noted Hadnot neither references Shankle nor addresses unconscionability. || Misrepresented: Case Law | Brown asserted Circuit City acknowledged that 'inequality of bargaining power' is a significant enforcement consideration; the Court explained the cited passage instead discussed the benefits of enforcing employment arbitration agreements.

Details

Although no immediate sanctions were imposed, Magistrate Judge Ho explicitly warned Plaintiff that future misconduct of this nature may violate Rule 11 and lead to consequences.

Sanction teardown · S.D. Texas, USA · 2025-04-22

Brown v. Patel et al.

What happened

In S.D. Texas, 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)

Defendants reported Brown’s brief cited five nonexistent cases; the Court cautioned him about Rule 11.
Misrepresented (Case Law)

Brown claimed Hadnot v. Bay 'cited approvingly' Shankle and recognized cost-splitting/confidentiality/discovery limits as unconscionable; the Court noted Hadnot neither references Shankle nor addresses unconscionability.
Misrepresented (Case Law)

Brown asserted Circuit City acknowledged that 'inequality of bargaining power' is a significant enforcement consideration; the Court explained the cited passage instead discussed the benefits of enforcing employment arbitration agreements.

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

Additional detail

Although no immediate sanctions were imposed, Magistrate Judge Ho explicitly warned Plaintiff that future misconduct of this nature may violate Rule 11 and lead to consequences.

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/348/Brown_v._Patel_S.D._Texas_USA_April_22_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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