Sanction teardown · M.D. Florida, USA · 2025-12-02
De Ford, Bader, and Key v. James Koutoulas and LGBCoin, LTD
What happened
In M.D. Florida, 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)Defendants cited this opinion to support their 'meme coin' argument; the Court could not locate the decision and found the citation likely fabricated, warning that citing non-existent cases is sanctionable.
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Fabricated (Case Law)Defendants relied on this purported S.D.N.Y. decision; the Court's independent research could not find the opinion and concluded the citation appears fabricated.
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Fabricated (Case Law)Plaintiffs also identified this cited decision as non-existent; the Court noted the additional alleged hallucinated citation and admonished defendants for failing to dispute the allegation.
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
Warning
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/1121/De_Ford_v._Koutoulas_USA_2_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).