Sanction teardown · E.D. Texas, USA · 2025-10-10
David R. Pete v. United States Department of Justice, et al.
What happened
In E.D. Texas, 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:
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Fabricated (Case Law)Plaintiff cited a case in his objections that the court could not locate; plaintiff later claimed he had submitted authentic copies but attached none; the court concluded the citation was AI-generated and fake.
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Fabricated (Case Law)A second case citation in the plaintiff's objections likewise could not be verified; the court found it to be an AI-hallucinated fake opinion and declined to rely on objections based on it.
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
Magistrate Judge's recommendation adopted; in forma pauperis denied; plaintiff ordered to pay $405 filing fee within 10 days or the case will be dismissed.
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.
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Source: https://www.damiencharlotin.com/documents/873/Pete_v._DOJ_USA_10_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).