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Eric Andrew Perez v. Dr. Neil C. Evans, et al.

Court
S.D. New York
Jurisdiction
USA
Decided
2025-09-25
AI tool
ChatGPT
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff attributed a quotation to 'Concepcion v. City of New York, No. 05 Civ. 8501 (RJS), 2008 WL 5395720, at *4 (S.D.N.Y. Dec. 17, 2008),' but no such December 17, 2008 S.D.N.Y. opinion exists; the quoted language actually appears in Armco, Inc. v. Penrod-Stauffer Building Systems, Inc., 733 F.2d 1087, 1089 (4th Cir. 1984). Court treated this citation as a hallucinated/fabricated citation and noted the misattribution and omission of context. || Misrepresented: Case Law | Plaintiff cited 'United States v. Peterson, No. 3:17-cr-00065 (D. Conn. 2018)' and claimed the case supported a proposition about deception vitiating consent; the docket cited corresponds to United States v. Cook and the Peterson citation appears scrambled; the actual Peterson decision (No. 3:18-CR-00049, 2018 WL 6061571) holds the opposite of Plaintiff's asserted rule. Court treated this as an AI-generated misrepresentation/scrambled citation and noted the holding contradicted Plaintiff's use.

Sanction teardown · S.D. New York, USA · 2025-09-25

Eric Andrew Perez v. Dr. Neil C. Evans, et al.

What happened

In S.D. New York, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Plaintiff attributed a quotation to 'Concepcion v. City of New York, No. 05 Civ. 8501 (RJS), 2008 WL 5395720, at *4 (S.D.N.Y. Dec. 17, 2008),' but no such December 17, 2008 S.D.N.Y. opinion exists; the quoted language actually appears in Armco, Inc. v. Penrod-Stauffer Building Systems, Inc., 733 F.2d 1087, 1089 (4th Cir. 1984). Court treated this citation as a hallucinated/fabricated citation and noted the misattribution and omission of context.
  • Misrepresented (Case Law)
    Plaintiff cited 'United States v. Peterson, No. 3:17-cr-00065 (D. Conn. 2018)' and claimed the case supported a proposition about deception vitiating consent; the docket cited corresponds to United States v. Cook and the Peterson citation appears scrambled; the actual Peterson decision (No. 3:18-CR-00049, 2018 WL 6061571) holds the opposite of Plaintiff's asserted rule. Court treated this as an AI-generated misrepresentation/scrambled citation and noted the holding contradicted Plaintiff's use.

Which AI tool

ChatGPT. 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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/823/ERIC_ANDREW_PEREZ_Plaintiff_v_DR_NEIL_C_EVANS_et_al_Defendants.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/823/ERIC_ANDREW_PEREZ_Plaintiff_v_DR_NEIL_C_EVANS_et_al_Defendants.pdf

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