What was hallucinated

Fabricated: Case Law | Plaintiff's TRO motion cited a nonexistent Ninth Circuit case; court identified the citation as fabricated and noted AI drafting.

Details

The court determined Plaintiff's emergency motion for a temporary restraining order was apparently drafted using generative AI and contained bracketed placeholders and a fabricated case citation ("Corrigan v. City of Scottsdale, 720 F.3d 513, 520 (9th Cir. 2013)"). The court noted this raised Federal Rule of Civil Procedure 11 concerns but, for judicial efficiency, addressed the motion on the merits, denied the TRO, and dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B). No professional sanctions or monetary penalties were imposed related to the fabricated citation.

Sanction teardown · E.D. Missouri, USA · 2026-07-10

Holmes v. Cape Meadows Apartments HRMS

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)

Plaintiff's TRO motion cited a nonexistent Ninth Circuit case; court identified the citation as fabricated and noted AI drafting.

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.

Additional detail

The court determined Plaintiff's emergency motion for a temporary restraining order was apparently drafted using generative AI and contained bracketed placeholders and a fabricated case citation ("Corrigan v. City of Scottsdale, 720 F.3d 513, 520 (9th Cir. 2013)"). The court noted this raised Federal Rule of Civil Procedure 11 concerns but, for judicial efficiency, addressed the motion on the merits, denied the TRO, and dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B). No professional sanctions or monetary penalties were imposed related to the fabricated citation.

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.

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Source: https://www.damiencharlotin.com/documents/2605/Holmes_v._Meadows_USA_10_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).