Sanction teardown · E.D. Michigan, USA · 2025-08-19

Clark v. JPMorgan Chase Bank, N.A.

What happened

In E.D. Michigan, 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)
  Court found the citation 'United States v. Provident Bank, 2021 WL 1985046, at 2 (E.D. Mich. May 18, 2021)' cannot be located and likely does not exist.
• Fabricated (Case Law)
  Court identified 'Gibson v. Rosati, 2017 WL 1155765 (N.D.N.Y. Mar. 27, 2017)' as a citation that does not appear to exist or is not retrievable.
• Fabricated (Case Law)
  Court noted 'Jones v. TransUnion LLC, 2022 WL 407915 (E.D. Mich. Feb. 10, 2022)' as a referenced citation that could not be located and may be fictitious.
• Misrepresented (Case Law)
  Court observed Beaudry v. TeleCheck Servs., Inc., 579 F.3d 702 (6th Cir. 2009) was cited by the plaintiff for a principle the case does not address (misapplied precedent).

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

Plaintiff's motion denied as frivolous; reply and sur-reply struck; plaintiff ordered to show cause

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/735/Clark_v_JPMorgan_Chase_Bank_NA_USA_19_August_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).