Sanction teardown · CA Illinois, USA · 2025-12-29
In re S.A., D.H., and B.M., Minors
What happened
In CA Illinois, 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:
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False Quotes (Case Law)Respondent cited a fictitious quote from In re A.S., asserting 'Reasonable progress does not require complete agreement with the Department's version of events,' which the court found not present in that decision.
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False Quotes (Case Law)Respondent attributed a fabricated quote to In re J.L., claiming 'Parents may dispute details of the incident while still making progress toward correcting the conditions that led to removal,' which the court said J.L. did not address.
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False Quotes (Case Law)Respondent drew a fictitious conclusion from In re M.A., quoting that termination "cannot rest on a parent's personality traits or imperfect cooperation unless those conditions prevent the parent from safely parenting," which the court found was not in M.A.
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False Quotes (Case Law)Respondent attributed the quote 'A parent is not required to parrot the agency's exact narrative.' to In re Brianna B.; the court found the quote fictitious and not addressed in that opinion.
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
Warning
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/1230/In_re_SA_USA_29_December_2025_-_ECF_96.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).