What was hallucinated

False Quotes: Case Law | Quoted Infuturia as stating removal is proper when the arbitration clause or award is raised in defense rather than the complaint; court found the quoted sentence does not appear in Infuturia. || False Quotes: Case Law | Quoted Jones Day v. Orrick as stating ‘‘a case need only relate to an arbitration agreement in the broadest sense’’; court found the phrase does not appear in the opinion. || False Quotes: Case Law | Quoted Jones Day as stating that if a Convention award ‘‘does not appear on the face of the complaint,’’ a ‘‘colorable defense relating to the award’’ is enough for federal jurisdiction; court found the phrase absent from the opinion. || False Quotes: Case Law | Quoted C.B.F. Industria de Gusa S/A v. AMCI Holdings as stating that recognition of an arbitral award and recognition of a foreign judgment enforcing that award are not mutually exclusive; court found the quoted phrase absent. || False Quotes: Case Law | Quoted National Aluminum Co. v. Peak Chemical as stating state judgment recognition statutes ‘‘do not override the provisions of the New York Convention or the FAA when those federal laws govern the underlying dispute’’; court found the phrase absent. || Misrepresented: Case Law | Cited Int'l Trading & Indus. Inv. Co. v. DynCorp Aerospace Tech. for the proposition that courts recognize the three-year limitations period under 9 U.S.C. § 207, though that case does not address the statute of limitations.

Details

"Counsel should take seriously its obligation to provide the Court with an accurate description of the law. See, e.g., United States v. Hayes, 763 F. Supp. 3d 1054 (E.D. Cal. 2025) (levying $1,500 in monetary sanctions against counsel personally for fictitious cases and quotations that the court suspected were produced using artificial intelligence),reconsideration denied, No. 2:24-CR-0280-DJC, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025); Grant v. City of Long Beach, 96 F.4th 1255 (9th Cir. 2024) (striking an appellant's brief and dismissing an appeal for materially misrepresenting or fabricating case citations). After New Materials freely accused opposing counsel of misstating the law, New Materials’ submission of non-existent quotes is troubling (Dkt. 30 at 5 (“Chenco's argument for remand collapses under the weight of its own misreading of the law”); id.at 7 (“Chenco fundamentally misrepresents the applicable removal standard”); Dkt. 34 at 1 (“The proposed sur-reply ... is necessary to address new legal misstatements ....”); id. at 2-3 (“Chenco's failure to address this standard ... misstates controlling law and warrants correction.”)). Accordingly, the Court reminds counsel of their duties to act according to the Idaho Rules of Professional Conduct."

Sanction teardown · D. Idaho, USA · 2025-08-22

Chenco v. Do-Fluoride

What happened

In D. Idaho, 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)

Quoted Infuturia as stating removal is proper when the arbitration clause or award is raised in defense rather than the complaint; court found the quoted sentence does not appear in Infuturia.
False Quotes (Case Law)

Quoted Jones Day v. Orrick as stating ‘‘a case need only relate to an arbitration agreement in the broadest sense’’; court found the phrase does not appear in the opinion.
False Quotes (Case Law)

Quoted Jones Day as stating that if a Convention award ‘‘does not appear on the face of the complaint,’’ a ‘‘colorable defense relating to the award’’ is enough for federal jurisdiction; court found the phrase absent from the opinion.
False Quotes (Case Law)

Quoted C.B.F. Industria de Gusa S/A v. AMCI Holdings as stating that recognition of an arbitral award and recognition of a foreign judgment enforcing that award are not mutually exclusive; court found the quoted phrase absent.
False Quotes (Case Law)

Quoted National Aluminum Co. v. Peak Chemical as stating state judgment recognition statutes ‘‘do not override the provisions of the New York Convention or the FAA when those federal laws govern the underlying dispute’’; court found the phrase absent.
Misrepresented (Case Law)

Cited Int'l Trading & Indus. Inv. Co. v. DynCorp Aerospace Tech. for the proposition that courts recognize the three-year limitations period under 9 U.S.C. § 207, though that case does not address the statute of limitations.

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

Court denied defendant's motion for leave to file a surreply, admonished counsel for submitting non-existent quotations, and granted plaintiff's motion to remand.

Additional detail

"Counsel should take seriously its obligation to provide the Court with an accurate description of the law. See, e.g., United States v. Hayes, 763 F. Supp. 3d 1054 (E.D. Cal. 2025) (levying $1,500 in monetary sanctions against counsel personally for fictitious cases and quotations that the court suspected were produced using artificial intelligence),reconsideration denied, No. 2:24-CR-0280-DJC, 2025 WL 1067323 (E.D. Cal. Apr. 9, 2025); Grant v. City of Long Beach, 96 F.4th 1255 (9th Cir. 2024) (striking an appellant's brief and dismissing an appeal for materially misrepresenting or fabricating case citations). After New Materials freely accused opposing counsel of misstating the law, New Materials’ submission of non-existent quotes is troubling (Dkt. 30 at 5 (“Chenco's argument for remand collapses under the weight of its own misreading of the law”); id.at 7 (“Chenco fundamentally misrepresents the applicable removal standard”); Dkt. 34 at 1 (“The proposed sur-reply ... is necessary to address new legal misstatements ....”); id. at 2-3 (“Chenco's failure to address this standard ... misstates controlling law and warrants correction.”)). Accordingly, the Court reminds counsel of their duties to act according to the Idaho Rules of Professional Conduct."

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/738/Chenco_v._Do-Fluoride_USA_22_August_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).