Sanction teardown · M.D. North Carolina (Bankruptcy), USA · 2025-11-18

In re Bryant

What happened

In M.D. North Carolina (Bankruptcy), 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)
  Debtors cited a non-existent case 'Harrison v. Hinson, 338, 352 S.E.2d 836 (1987)'; Court noted no such citation exists and that the likely intended case (Harris v. Hinson) is inapposite to Debtors' proposition.
• Fabricated (Case Law)
  Debtors cited 'In re Weiman, 22 F.3d 135 (7th Cir. 1994)', but the case and caption are incorrect (the cited opinion corresponds to Kirk v. Fed. Prop. Mgmt. Corp.); Court found the citation does not support Debtors' proposition.
• Fabricated (Case Law)
  Debtors relied on 'In re Schmid, No. 10-12142, 2013 WL 4835463 (Bankr. W.D. Wis. Sept. 5, 2013)', which the Court found is not an authentic Westlaw citation as presented and whose orders do not support Debtors' asserted proposition.
• False Quotes (Case Law)
  Debtors attributed a quotation to In re Symington, 209 B.R. 678, 689 (Bankr. D. Md. 1997) that does not appear in that opinion; Court identified the misquote.
• Misrepresented (Case Law)
  Debtors cited 'Pulley v. Pulley, 254 N.C. 714 (1961)' — citation is inaccurate though the underlying case exists and the Court corrected the proper citation and discussed its limited relevance.

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

Show Cause 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/1059/In_re_Bryant_USA_19_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).