Skip to main content
Citation Safe

Was Evans on the other side of your case?

Check their next brief before they file — Opposition Check verifies every citation in a filed brief for $49, no signup. Get Opposition Check →

Evans v. Robertson (4)

Court
E.D. Michigan
Jurisdiction
USA
Decided
2026-07-21
AI tool
Implied
Outcome
Briefs (both sides) struck
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Plaintiff cites Mitan v. Campbell as supporting that republication can extend accrual; the court notes Mitan holds the opposite (accrual is not extended by republication). || Misrepresented: Case Law | Defendant cites Delay for the proposition that plaintiff bears the burden of establishing diversity jurisdiction; the court explains Delay does not support that statement. || Misrepresented: Case Law | Defendant cites Everett for the contention that plaintiff bears the burden to show the amount in controversy exceeds $75,000; the court notes Everett states a different allocation of burden (defendant seeking removal bears it).

Details

The Court found both Plaintiff's and Defendant's filings contained factitious citations and misrepresentations of precedent despite prior orders requiring verification; examples include a misstatement of Mitan v. Campbell and improper uses of Delay and Everett. The Court struck the objections and related filings, reiterated prior sanctions (imposed Nov. 20, 2025), and warned that further violations may incur additional sanctions. The Court ruled that even a single factitious citation violates its orders and justifies striking filings.

Sanction teardown · E.D. Michigan, USA · 2026-07-21

Evans v. Robertson (4)

What happened

In E.D. Michigan, 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:

  • Misrepresented (Case Law)
    Plaintiff cites Mitan v. Campbell as supporting that republication can extend accrual; the court notes Mitan holds the opposite (accrual is not extended by republication).
  • Misrepresented (Case Law)
    Defendant cites Delay for the proposition that plaintiff bears the burden of establishing diversity jurisdiction; the court explains Delay does not support that statement.
  • Misrepresented (Case Law)
    Defendant cites Everett for the contention that plaintiff bears the burden to show the amount in controversy exceeds $75,000; the court notes Everett states a different allocation of burden (defendant seeking removal bears 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

Briefs (both sides) struck

Additional detail

The Court found both Plaintiff's and Defendant's filings contained factitious citations and misrepresentations of precedent despite prior orders requiring verification; examples include a misstatement of Mitan v. Campbell and improper uses of Delay and Everett. The Court struck the objections and related filings, reiterated prior sanctions (imposed Nov. 20, 2025), and warned that further violations may incur additional sanctions. The Court ruled that even a single factitious citation violates its orders and justifies striking filings.

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://reason.com/volokh/2026/07/21/ive-seen-fake-cites-on-both-sides-now-ii/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://reason.com/volokh/2026/07/21/ive-seen-fake-cites-on-both-sides-now-ii/

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checkerBack to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49Sanctions-motion template