What was hallucinated

False Quotes: Case Law | Petitioners quoted Oates v. National Bank as stating banks 'may only deal in negotiable instruments and lawful money'; court found no such quote in Oates (100 U.S. 239 (1879)). || Misrepresented: Case Law | Petitioners attributed to National Bank v. Matthews a statement that banks 'cannot lend their credit to another'; court found the cited case (98 U.S. 621 (1878)) does not contain that statement. || Fabricated: Case Law | Petitioners cited 'Commercial Bank of Cleveland v. Ely (1853)'; court could not locate that case and found the similar Commercial Bank of Cleveland v. Iola, 154 U.S. 617 (1875) does not contain the quoted language. || Fabricated: Case Law | Petitioners repeatedly quoted 'Federal Reserve Bank of San Francisco v. United States (1919)'; court was unable to locate any case with that name or date. || Misrepresented: Case Law | Petitioners cited 'Glover v. Standard Oil Co., 65 N.E.2d 389 (Ind. 1946)' to support that an unrebutted affidavit stands as truth; court traced citation to a different reported opinion which does not support that proposition. || Misrepresented: Case Law | Petitioners cited Bank of Augusta v. Earle and Merchants' Bank v. State Bank as holding a bank that lends credit acts beyond its charter; court found those cases do not hold that proposition. || Fabricated: Case Law | Petitioners cited 'Farmers' & Mechanics' Bank v. Smith (1819)'; court could not locate any such case and noted the closest is an 1821 case that does not support petitioners' claims.

Sanction teardown · E.D. Wisconsin, USA · 2025-12-18

Gerou v. George, Whitten, and United States

What happened

In E.D. Wisconsin, 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:

False Quotes (Case Law)

Petitioners quoted Oates v. National Bank as stating banks 'may only deal in negotiable instruments and lawful money'; court found no such quote in Oates (100 U.S. 239 (1879)).
Misrepresented (Case Law)

Petitioners attributed to National Bank v. Matthews a statement that banks 'cannot lend their credit to another'; court found the cited case (98 U.S. 621 (1878)) does not contain that statement.
Fabricated (Case Law)

Petitioners cited 'Commercial Bank of Cleveland v. Ely (1853)'; court could not locate that case and found the similar Commercial Bank of Cleveland v. Iola, 154 U.S. 617 (1875) does not contain the quoted language.
Fabricated (Case Law)

Petitioners repeatedly quoted 'Federal Reserve Bank of San Francisco v. United States (1919)'; court was unable to locate any case with that name or date.
Misrepresented (Case Law)

Petitioners cited 'Glover v. Standard Oil Co., 65 N.E.2d 389 (Ind. 1946)' to support that an unrebutted affidavit stands as truth; court traced citation to a different reported opinion which does not support that proposition.
Misrepresented (Case Law)

Petitioners cited Bank of Augusta v. Earle and Merchants' Bank v. State Bank as holding a bank that lends credit acts beyond its charter; court found those cases do not hold that proposition.
Fabricated (Case Law)

Petitioners cited 'Farmers' & Mechanics' Bank v. Smith (1819)'; court could not locate any such case and noted the closest is an 1821 case that does not support petitioners' claims.

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.

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

Source: https://www.damiencharlotin.com/documents/1197/Gerou_et_al._v._George_USA_18_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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