What was hallucinated

Misrepresented: Case Law | Debtor described Walters as allowing amendment to retroactively change initial plan payments; court found Walters does not support that claim and was decided before BAPCPA. || Misrepresented: Case Law | Debtor relied on Cobb as supporting delayed payment relief; court found Cobb pre-dated BAPCPA and is distinguishable. || Fabricated: Case Law | Debtor cited a Vega-Lara citation and described a holding favorable to him; the court found the citation/number mismatched and that there is no Vega-Lara case saying what debtor claimed. || Fabricated: Case Law | Debtor cited 'Segarra-Miranda v. Acosta-Rivera, 597 F.3d 1' but the cited reporter/number corresponds to a different case; court found the citation incorrect/misleading.

Sanction teardown · D. Oregon (Bankruptcy), USA · 2025-07-07

In re Eugene Ezra Perkins

What happened

In D. Oregon (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:

Misrepresented (Case Law)

Debtor described Walters as allowing amendment to retroactively change initial plan payments; court found Walters does not support that claim and was decided before BAPCPA.
Misrepresented (Case Law)

Debtor relied on Cobb as supporting delayed payment relief; court found Cobb pre-dated BAPCPA and is distinguishable.
Fabricated (Case Law)

Debtor cited a Vega-Lara citation and described a holding favorable to him; the court found the citation/number mismatched and that there is no Vega-Lara case saying what debtor claimed.
Fabricated (Case Law)

Debtor cited 'Segarra-Miranda v. Acosta-Rivera, 597 F.3d 1' but the cited reporter/number corresponds to a different case; court found the citation incorrect/misleading.

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

Case dismissed; motion to alter or amend denied

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/1784/In_re_perkins.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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