Sanction teardown · D. Maine, USA · 2025-07-24

Everett J. Prescott, Inc. v. Timothy J. Beall

What happened

In D. Maine, 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:

• Fabricated (Case Law)
  Defendant's filings contained fictitious case citations; Court's order to show cause found filings replete with such fabrications.
• False Quotes (Case Law)
  Defendant included factitious legal quotations attributed to authorities; Court identified these as false quotations.
• Misrepresented (Case Law)
  Defendant mischaracterized legal precedent in his submissions; Court expressly found mischaracterizations.
• Misrepresented (Legal Norm)
  Defendant mischaracterized rules of civil procedure; Court identified misstatements of procedural rules.
• Fabricated (Case Law)
  Defendant admitted using AI that generated invented or hallucinated citations and that his prior citations/quotes were inaccurate or improperly sourced.

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

The court imposed a requirement for future filings to include a written representation of citation accuracy.

Additional detail

Timothy J. Beall, a pro se litigant, admitted to using AI software to generate filings with fabricated citations. The court did not impose monetary sanctions but required Beall to include a written representation of citation accuracy in future filings. The court acknowledged the challenges faced by pro se litigants but emphasized the responsibility to ensure accurate legal citations.

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/640/Prescott_v._Beall_USA_24_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).