What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Keller v. Bd. of Educ., 182 F.R.D. 871 (D.N.M. 1998)' in multiple filings; the court found that citation does not exist (a similarly named, different-year decision exists). || Fabricated: Case Law | Plaintiff cited 'Ford v. BNSF Ry. Co., 709 F.3d 715 (10th Cir. 2013)' in multiple filings; the court found this reported Tenth Circuit citation does not exist (similar-named but different case exists in another court). || Fabricated: Case Law | Plaintiff cited 'Rogers v. NYU Langone Hospitals, 2023 WL 2705769' in his first motion for sanctions; the court found this case does not exist and Defendant had pointed this out.

Details

Sanction confirmed later (here) with costs decided in March 2026.

Sanction teardown · D. New Mexico, USA · 2025-11-25

Carlos Maturin v. T-Mobile USA, Inc.

What happened

In D. New Mexico, 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)

Plaintiff cited 'Keller v. Bd. of Educ., 182 F.R.D. 871 (D.N.M. 1998)' in multiple filings; the court found that citation does not exist (a similarly named, different-year decision exists).
Fabricated (Case Law)

Plaintiff cited 'Ford v. BNSF Ry. Co., 709 F.3d 715 (10th Cir. 2013)' in multiple filings; the court found this reported Tenth Circuit citation does not exist (similar-named but different case exists in another court).
Fabricated (Case Law)

Plaintiff cited 'Rogers v. NYU Langone Hospitals, 2023 WL 2705769' in his first motion for sanctions; the court found this case does not exist and Defendant had pointed this out.

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

Adverse Costs Order (monetary penalty: 8640 USD.)

Additional detail

Sanction confirmed later (here) with costs decided in March 2026.

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/1092/Maturin_v._T-Mobile_USA_25_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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