What was hallucinated

Fabricated: Case Law | Court could not locate case || Fabricated: Case Law | Court could not locate case || Fabricated: Case Law | Court could not locate case

Details

"The danger of Attorney Stich’s AI use is especially felt here because his opponent’s pro se status meant that there was not an adversary capable of calling the attention of the court to the phony citations. Furthermore, this court expended time and resources in investigating the hallucinated citations, resources that could have been better spent adjudicating the merits of this underlying litigation and that of other cases pending before this court. The oversight in submitting fake citations is more than just sloppy lawyering: it imperils the integrity of our judicial process.However, the court also acknowledges that our society sits on the precipice of rapid technological development and that the continued development of AI will fundamentally alter life as we know it. Just as the advent of the Internet in the late 20th century transformed the legal profession, and particularly legal research, so too will artificial intelligence. Indeed, the two biggest legal research databases, Westlaw and LexisNexis, have developed and continue to expand their own proprietary AI tools to assist legal practitioners in finding case law.2 This Order should not be construed as a Luddite attack on technology and the efficiency it brings to the legal profession. Rather, this Order is an acknowledgement that AI remains a nascent technology with questionable reliability at this juncture. Given the ethical obligations lawyers must honor, it is imperative that lawyers use AI with diligence and care. This technology is too unsophisticated and must necessarily yield to a lawyer’s obligation of candor to the court."

Sanction teardown · D. Connecticut, USA · 2025-11-17

Cojom v. Roblen

What happened

In D. Connecticut, 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 could not locate case
Fabricated (Case Law)

Court could not locate case
Fabricated (Case Law)

Court could not locate case

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

Monetary sanction (monetary penalty: 500 USD.)

Additional detail

"The danger of Attorney Stich’s AI use is especially felt here because his opponent’s pro se status meant that there was not an adversary capable of calling the attention of the court to the phony citations. Furthermore, this court expended time and resources in investigating the hallucinated citations, resources that could have been better spent adjudicating the merits of this underlying litigation and that of other cases pending before this court. The oversight in submitting fake citations is more than just sloppy lawyering: it imperils the integrity of our judicial process.However, the court also acknowledges that our society sits on the precipice of rapid technological development and that the continued development of AI will fundamentally alter life as we know it. Just as the advent of the Internet in the late 20th century transformed the legal profession, and particularly legal research, so too will artificial intelligence. Indeed, the two biggest legal research databases, Westlaw and LexisNexis, have developed and continue to expand their own proprietary AI tools to assist legal practitioners in finding case law.2 This Order should not be construed as a Luddite attack on technology and the efficiency it brings to the legal profession. Rather, this Order is an acknowledgement that AI remains a nascent technology with questionable reliability at this juncture. Given the ethical obligations lawyers must honor, it is imperative that lawyers use AI with diligence and care. This technology is too unsophisticated and must necessarily yield to a lawyer’s obligation of candor to the court."

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/1045/Cojom_v._Roblen_USA_17_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).