What was hallucinated

False Quotes: Case Law | Plaintiff attributed seven quotations to cases that do not contain those quotations; the court found these to be fabricated or misattributed quotations relied on in his motion papers. || Fabricated: Case Law | Plaintiff cited “Loeb v Loeb, 84 AD2d 591 (2d Dept 1981)” and attributed a quotation to it; the court found 84 AD2d 591 corresponds to unrelated 3rd Dept decisions (Sanginario; First Depot) and the cited Loeb decision/quotation does not exist as represented. || Fabricated: Case Law | Plaintiff relied on a dozen purported authorities that the court and opposing counsel identified as nonexistent case citations listed in defense filings (NYSCEF Doc No. 102).

Sanction teardown · SC New York, USA · 2025-12-04

Hilpert v. 16 Judge SPV LLC

What happened

In SC New York, 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)

Plaintiff attributed seven quotations to cases that do not contain those quotations; the court found these to be fabricated or misattributed quotations relied on in his motion papers.
Fabricated (Case Law)

Plaintiff cited “Loeb v Loeb, 84 AD2d 591 (2d Dept 1981)” and attributed a quotation to it; the court found 84 AD2d 591 corresponds to unrelated 3rd Dept decisions (Sanginario; First Depot) and the cited Loeb decision/quotation does not exist as represented.
Fabricated (Case Law)

Plaintiff relied on a dozen purported authorities that the court and opposing counsel identified as nonexistent case citations listed in defense filings (NYSCEF Doc No. 102).

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

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/1236/Hilpert_v_16_Judge_SPV_LLC_USA_4_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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