What was hallucinated

Misrepresented: Case Law | Plaintiff cited Kirkland v. American Title Ins. Co., "692 F. Supp. 153, 155 (N.D. Ill. 1988)"; court found the case was decided in the E.D.N.Y. and the opinion contains no discussion of certified mail, so the citation does not support the proposition. || Fabricated: Case Law | Plaintiff cited United States v. Balan, 2013 WL 5539296 (N.D. Ill. Oct. 7, 2013); court found the Westlaw number yields Trahan v. Verret (La. App. Ct. 2013) and no matching N.D. Ill. decision exists — citation incorrect/likely fabricated. || Misrepresented: Legal Norm | Plaintiff relied on 735 ILCS 5/2-203.1 to argue certified mail is effective service; court explained the statute only permits moving for alternative service authorization and does not itself authorize service by certified mail. || Misrepresented: Case Law | Plaintiff cited People ex rel. Devine v. $30,700.00 U.S. Currency, 199 Ill. 2d 142 (2002); court noted Devine is an Illinois forfeiture case governed by different statutes about notice of forfeiture and is inapposite to service of process. || Misrepresented: Case Law | Plaintiff cited In re Marriage of Schmitt, 391 Ill. App. 3d 1010 (2d Dist. 2009); court found Schmitt concerns dissolution of marriage and contains no discussion of service by certified mail, making the citation irrelevant. || Misrepresented: Legal Norm | Plaintiff cited 735 ILCS 5/2-203.1 as authorizing service by certified mail; the court explained the statute only allows seeking authorization for alternative service and does not authorize certified-mail service without a court order. || Misrepresented: Case Law | Plaintiff cited Kirkland v. American Title Ins. Co., '692 F. Supp. 153, 155 (N.D. Ill. 1988)' to support certified-mail service; the court found the opinion was from the Eastern District of New York and contains no discussion of certified mail, so the citation was misapplied/misrepresented. || Fabricated: Case Law | Plaintiff cited 'United States v. Balan, 2013 WL 5539296 (N.D. Ill. Oct. 7, 2013)'; the court found the Westlaw number corresponds to a Louisiana appellate case (Trahan v. Verret) and no Northern District of Illinois decision by that title exists, indicating a fabricated or incorrect citation. || Misrepresented: Case Law | Plaintiff cited In re Marriage of Schmitt, 391 Ill. App. 3d 1010 (2d Dist. 2009) for the proposition that certified mail effected service; the court observed Schmitt concerns marital dissolution and contains no discussion of service by certified mail, so the case was inapposite/misrepresented.

Sanction teardown · N.D. Illinois, USA · 2025-04-11

Graciela Dela Torre v. Davies Life & Health, Inc., et al.

What happened

In N.D. Illinois, 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 cited Kirkland v. American Title Ins. Co., "692 F. Supp. 153, 155 (N.D. Ill. 1988)"; court found the case was decided in the E.D.N.Y. and the opinion contains no discussion of certified mail, so the citation does not support the proposition.
Fabricated (Case Law)

Plaintiff cited United States v. Balan, 2013 WL 5539296 (N.D. Ill. Oct. 7, 2013); court found the Westlaw number yields Trahan v. Verret (La. App. Ct. 2013) and no matching N.D. Ill. decision exists — citation incorrect/likely fabricated.
Misrepresented (Legal Norm)

Plaintiff relied on 735 ILCS 5/2-203.1 to argue certified mail is effective service; court explained the statute only permits moving for alternative service authorization and does not itself authorize service by certified mail.
Misrepresented (Case Law)

Plaintiff cited People ex rel. Devine v. $30,700.00 U.S. Currency, 199 Ill. 2d 142 (2002); court noted Devine is an Illinois forfeiture case governed by different statutes about notice of forfeiture and is inapposite to service of process.
Misrepresented (Case Law)

Plaintiff cited In re Marriage of Schmitt, 391 Ill. App. 3d 1010 (2d Dist. 2009); court found Schmitt concerns dissolution of marriage and contains no discussion of service by certified mail, making the citation irrelevant.
Misrepresented (Legal Norm)

Plaintiff cited 735 ILCS 5/2-203.1 as authorizing service by certified mail; the court explained the statute only allows seeking authorization for alternative service and does not authorize certified-mail service without a court order.
Misrepresented (Case Law)

Plaintiff cited Kirkland v. American Title Ins. Co., '692 F. Supp. 153, 155 (N.D. Ill. 1988)' to support certified-mail service; the court found the opinion was from the Eastern District of New York and contains no discussion of certified mail, so the citation was misapplied/misrepresented.
Fabricated (Case Law)

Plaintiff cited 'United States v. Balan, 2013 WL 5539296 (N.D. Ill. Oct. 7, 2013)'; the court found the Westlaw number corresponds to a Louisiana appellate case (Trahan v. Verret) and no Northern District of Illinois decision by that title exists, indicating a fabricated or incorrect citation.
Misrepresented (Case Law)

Plaintiff cited In re Marriage of Schmitt, 391 Ill. App. 3d 1010 (2d Dist. 2009) for the proposition that certified mail effected service; the court observed Schmitt concerns marital dissolution and contains no discussion of service by certified mail, so the case was inapposite/misrepresented.

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

Not specified in source record.

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/1602/Dela_Torre_v._Nippon_Life_USA_11_April_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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