In re: Loletha Hale, Esq. (Boston v. Williams)

Court

N.D. Georgia

Jurisdiction

USA

Decided

2025-10-28

AI tool

Implied

Outcome

Order to notify clients; Order to file this opinion in all new cases for five years

Monetary penalty

None reported

What was hallucinated

Misrepresented: Case Law | Cited Scanlan v. Tate Supply, Inc., 303 Ga. App. 9 (2010) as holding due diligence in service is a jury question; court found Scanlan holds the opposite (diligence is for the trial court). || Misrepresented: Case Law | Cited Akuoko v. Martin, 298 Ga. App. 364 (2009) as supporting that due diligence is a jury question; court noted Akuoko actually treats diligence as a question for the trial court. || Fabricated: Case Law | Cited Jenkins v. Roper, 313 Ga. App. 189 (2011); court found no such case at that citation and treated it as a non-existent/miscited authority.

Details

Party later filed for reconsideration, arguing that the judge had been biased; this failed (see here).

Sanction teardown · N.D. Georgia, USA · 2025-10-28

In re: Loletha Hale, Esq. (Boston v. Williams)

What happened

In N.D. Georgia, 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)

Cited Scanlan v. Tate Supply, Inc., 303 Ga. App. 9 (2010) as holding due diligence in service is a jury question; court found Scanlan holds the opposite (diligence is for the trial court).
Misrepresented (Case Law)

Cited Akuoko v. Martin, 298 Ga. App. 364 (2009) as supporting that due diligence is a jury question; court noted Akuoko actually treats diligence as a question for the trial court.
Fabricated (Case Law)

Cited Jenkins v. Roper, 313 Ga. App. 189 (2011); court found no such case at that citation and treated it as a non-existent/miscited authority.

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

Order to notify clients; Order to file this opinion in all new cases for five years

Additional detail

Party later filed for reconsideration, arguing that the judge had been biased; this failed (see here).

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/1012/Boston_et_al._v._Williams_USA_28_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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