What was hallucinated

False Quotes: Case Law | Counsel included quotations attributed to In re Vivendi Universal that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion. || False Quotes: Case Law | Counsel included quotations attributed to In re Parmalat that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion. || Fabricated: Case Law | Plaintiff counsel cited 'Midlantic Nat’l Bank v. Havens, 1994 WL 760822, at *4 (S.D.N.Y. Dec. 27, 1994)' to support unjust enrichment; the court found that Midlantic does not appear to exist. || Misrepresented: Case Law | Plaintiff counsel cited In re Refco, 826 F. Supp. 2d 478, 512 (S.D.N.Y. 2011) as supporting unjust enrichment; the court found that Refco does not mention unjust enrichment and thus was misused.

Sanction teardown · S.D. New York, USA · 2025-12-17

Burlingame v. Argo Private Client Group, Ltd. et al.

What happened

In S.D. New York, 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:

False Quotes (Case Law)

Counsel included quotations attributed to In re Vivendi Universal that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion.
False Quotes (Case Law)

Counsel included quotations attributed to In re Parmalat that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion.
Fabricated (Case Law)

Plaintiff counsel cited 'Midlantic Nat’l Bank v. Havens, 1994 WL 760822, at *4 (S.D.N.Y. Dec. 27, 1994)' to support unjust enrichment; the court found that Midlantic does not appear to exist.
Misrepresented (Case Law)

Plaintiff counsel cited In re Refco, 826 F. Supp. 2d 478, 512 (S.D.N.Y. 2011) as supporting unjust enrichment; the court found that Refco does not mention unjust enrichment and thus was misused.

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

Not specified in source record.

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/1254/Burlingame_v_ARGO_Private_Client_Group_USA_17_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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