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In re Jackson Hospital & Clinic, Inc., et al.

Court
M.D. Alabama (Bankruptcy)
Jurisdiction
USA
Decided
2025-11-20
AI tool
Unidentified
Outcome
Public Reprimand; Revocation of pro hac vice privileges; Order to Serve Order on Clients; Diffusion of Order to Counsel's Bars
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Court found pervasive fabricated citations in Progressive's Motion to Reconsider after comparing cited authorities to the arguments. || False Quotes: Case Law | Court identified false quotations attributed to legal authorities in the Motion to Reconsider (misstated or invented quotations). || Misrepresented: Legal Norm | Court found misleading and misrepresented statements of legal authority and doctrine in Progressive's filings, consistent with objections from DIP Lender and Debtors.

Details

Show Cause Order here. Law firm explained what happened here.In the ultimate order, the court noted that "In terms of competence, the threat to attorneys using generative artificial intelligence platforms powered by large language models is two-fold. First, danger exists that the attorney does not understand how the technology functions, believing that the output is real instead of “realistic-looking."."In finding that the law firm acted with integrity, the Court noted with approval that it had repaid the other side's fees, to the tune of 55,721.2 USD.

Sanction teardown · M.D. Alabama (Bankruptcy), USA · 2025-11-20

In re Jackson Hospital & Clinic, Inc., et al.

What happened

In M.D. Alabama (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)
    Court found pervasive fabricated citations in Progressive's Motion to Reconsider after comparing cited authorities to the arguments.
  • False Quotes (Case Law)
    Court identified false quotations attributed to legal authorities in the Motion to Reconsider (misstated or invented quotations).
  • Misrepresented (Legal Norm)
    Court found misleading and misrepresented statements of legal authority and doctrine in Progressive's filings, consistent with objections from DIP Lender and Debtors.

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

Public Reprimand; Revocation of pro hac vice privileges; Order to Serve Order on Clients; Diffusion of Order to Counsel's Bars

Additional detail

Show Cause Order here. Law firm explained what happened here.In the ultimate order, the court noted that "In terms of competence, the threat to attorneys using generative artificial intelligence platforms powered by large language models is two-fold. First, danger exists that the attorney does not understand how the technology functions, believing that the output is real instead of “realistic-looking."."In finding that the law firm acted with integrity, the Court noted with approval that it had repaid the other side's fees, to the tune of 55,721.2 USD.

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/1065/Jackson_Hospital__Clinic_USA_21_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1065/Jackson_Hospital__Clinic_USA_21_November_2025.pdf

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