What was hallucinated

Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition. || Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Goodman v. Liberty Mut. Fire Ins. Co., 2022 WL 4534416 (E.D. Mo. Sept. 28, 2022)' to support its argument; the Court found the citation does not exist and the intended Goodman case did not support the asserted proposition. || Misrepresented: Case Law | Liberty Mutual mischaracterized and partially misquoted Dhyne v. State Farm, asserting it supported cooperation clauses and EUO requirements when the cited decision does not address those issues as claimed. || Misrepresented: Doctrinal Work | Liberty Mutual cited sections of 30 Mo. Prac., Insurance Law & Practice (§§ 4:2, 4:8, 4:9) as supporting that cooperation clauses/EUO requirements are longstanding and give rise to a presumption of prejudice; the Court found those sections do not contain the claimed statements and were mischaracterized.

Details

From the Order to Show Cause (available here): "One week after filing its second motion for summary judgment, Liberty Mutual submitted a notice of errata identifying the erroneous Goodman and Chaudri citations and demonstrating legitimate citations to those cases. [ECF No. 50].3 While the Court acknowledges Liberty Mutual’s prompt notice disclosing the two most serious errors in its filing, the additional misquotations and mischaracterizations discussed above will not be disregarded. Liberty Mutual indicates that the errors were typographical and/or caused by vision impairment, but that explanation is simply not credible. The errors in Liberty Mutual’s filing are not ones in which a few letters or numbers were passed over or shuffled. Rather, the filing includes entire names, dates, court designations, and Westlaw citations that are completely off base, and various other inaccuracies cannot be explained by typographical or vision issues. Therefore, the Court will reserve its ruling on the motion for sanctions and will set a hearing requiring Liberty Mutual to show cause why it should not be sanctioned."Later on, the court accepted Counsel's technical audit that suggested the errors stemmed from a human, non-AI source.

Sanction teardown · E.D. Missouri, USA · 2025-11-17

Gittemeier v. Liberty Mutual Personal Insurance Company

What happened

In E.D. Missouri, 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)

Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition.
Fabricated (Case Law)

Liberty Mutual cited a non-existent case 'Goodman v. Liberty Mut. Fire Ins. Co., 2022 WL 4534416 (E.D. Mo. Sept. 28, 2022)' to support its argument; the Court found the citation does not exist and the intended Goodman case did not support the asserted proposition.
Misrepresented (Case Law)

Liberty Mutual mischaracterized and partially misquoted Dhyne v. State Farm, asserting it supported cooperation clauses and EUO requirements when the cited decision does not address those issues as claimed.
Misrepresented (Doctrinal Work)

Liberty Mutual cited sections of 30 Mo. Prac., Insurance Law & Practice (§§ 4:2, 4:8, 4:9) as supporting that cooperation clauses/EUO requirements are longstanding and give rise to a presumption of prejudice; the Court found those sections do not contain the claimed statements and were mischaracterized.

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

Costs Order + Fine; One Attorney ordered to withdraw (monetary penalty: 1000 USD.)

Additional detail

From the Order to Show Cause (available here): "One week after filing its second motion for summary judgment, Liberty Mutual submitted a notice of errata identifying the erroneous Goodman and Chaudri citations and demonstrating legitimate citations to those cases. [ECF No. 50].3 While the Court acknowledges Liberty Mutual’s prompt notice disclosing the two most serious errors in its filing, the additional misquotations and mischaracterizations discussed above will not be disregarded. Liberty Mutual indicates that the errors were typographical and/or caused by vision impairment, but that explanation is simply not credible. The errors in Liberty Mutual’s filing are not ones in which a few letters or numbers were passed over or shuffled. Rather, the filing includes entire names, dates, court designations, and Westlaw citations that are completely off base, and various other inaccuracies cannot be explained by typographical or vision issues. Therefore, the Court will reserve its ruling on the motion for sanctions and will set a hearing requiring Liberty Mutual to show cause why it should not be sanctioned."Later on, the court accepted Counsel's technical audit that suggested the errors stemmed from a human, non-AI source.

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/2025/10/16/repeated-nonexistent-cases-in-filing-from-20-lawyer-insurance-defense-firm/?nab=1, via Damien Charlotin's public AI Hallucination Cases Database (CC0).