What was hallucinated

Fabricated: Case Law | Debtor cited 'In re Miller, 150 B.R. 834 (Bankr. N.D. Ohio 1993)', which the Court found to be non-existent and noted 150 B.R. 834 corresponds to Brandt v. 440 Assocs., indicating a made-up citation; Court flagged this as a potential AI hallucination and basis for Rule 9011 review. || Misrepresented: Case Law | Debtor relied on In re Pan Am Corp., 159 B.R. 396, 400 (S.D.N.Y. 1993) for the proposition that status quo should be maintained pending withdrawal; Court found that Pan Am addressed Rule 54(b) and dismissal of appeals, not withdrawal/stay, so the authority was misapplied.

Sanction teardown · S.D. Ohio (Bankruptcy), USA · 2025-11-24

In re: Marguerite Latete Kilpatrick

What happened

In S.D. Ohio (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)

Debtor cited 'In re Miller, 150 B.R. 834 (Bankr. N.D. Ohio 1993)', which the Court found to be non-existent and noted 150 B.R. 834 corresponds to Brandt v. 440 Assocs., indicating a made-up citation; Court flagged this as a potential AI hallucination and basis for Rule 9011 review.
Misrepresented (Case Law)

Debtor relied on In re Pan Am Corp., 159 B.R. 396, 400 (S.D.N.Y. 1993) for the proposition that status quo should be maintained pending withdrawal; Court found that Pan Am addressed Rule 54(b) and dismissal of appeals, not withdrawal/stay, so the authority was misapplied.

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.

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/1091/In_re_Marguerite_Latete_Kilpatrick_Debtor_USA_24_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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