Sanction teardown · 250th Judicial District Court (Travis County, TX), USA · 2026-06-08
Erica Whitesock v. Bird Rides, Inc., Third Lane Mobility, Inc. d/b/a Bird Global, Inc., and The City of Austin
What happened
In 250th Judicial District Court (Travis County, TX), 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 (Legal Norm)Plaintiffs' brief contained a completely fabricated quotation attributed to the Texas Tort Claims Act; counsel admitted it was generated by an AI chatbot and copied without verification; court noted the fabrication.
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Misrepresented (Legal Norm)Plaintiffs cited CPRC §75.002(d) as waiving governmental immunity for gross negligence on public recreational land; the court agreed this was incorrect and noted the statute governs private landowner liability, not governmental immunity.
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
Court ordered Mr. Bradford Klager and his law firm Hilliard Law jointly and severally liable for $10,000 in attorney's fees to the City of Austin (and to provide a copy of the Order to his client). (monetary penalty: 1 .)
Additional detail
Plaintiffs' response to the City's plea contained a fabricated quotation falsely attributed to the Texas Tort Claims Act; Plaintiffs' counsel Bradford Klager admitted the quote was created by a generative AI chatbot and was copied without verification. The response also mischaracterized CPRC §75.002(d) as waiving governmental immunity when that provision addresses private landowner liability. The City identified these problems; the Court found counsel's conduct improper and awarded $10,000 in attorney's fees against Mr. Klager and his firm as an appropriate sanction.
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/2807/Whitesock_v._City_of_Austin_USA_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).