What was hallucinated

Fabricated: Case Law | Appellant cited "Sain v. Roo, 2018-Ohio-2878, ¶ 19," which the court found to be fictitious (no case assigned to that citation). || Fabricated: Case Law | Appellant cited "In re Whitaker, 36 Ohio App.3d 213 (1987)," but the court found this citation to be incorrect/fictitious (36 Ohio App.3d 213 is State v. Arvanitis). || Fabricated: Case Law | Appellant relied on "In re M.M., 2015-Ohio-2571" and another similar citation, which the court identified as fictitious/misassigned and not supporting appellant's propositions. || False Quotes: Case Law | Appellant attributed a quotation to Braatz v. Braatz, 85 Ohio St.3d 40 (1999), but the court found the quoted language does not appear in Braatz. || Fabricated: Case Law | Appellant cited "In re K.W., 2016-Ohio-5272, ¶ 16," which the court determined was mis-cited / assigned to a different case and did not support his claim. || Fabricated: Case Law | Appellant cited "In re J.J., 2017-Ohio-5467, ¶ 29," but the court noted no case is assigned to that citation. || Misrepresented: Case Law | Appellant referenced "State v. Smith, 2022-Ohio-1234," but the court observed that citation is assigned to a different case (In re Z.L.) and does not support appellant's asserted proposition. || Misrepresented: Case Law | Appellant cited "In re G.C., 2020-Ohio-4092" for legal propositions, but the court found that citation is assigned to an unrelated case (Oregon v. Gaughan) and does not support his claims. || False Quotes: Case Law | Appellant attributed a quotation/supportive language to In re Guardianship of Hollins, 114 Ohio St.3d 434 (2007), but the court found no such quotation in Hollins. || Misrepresented: Case Law | Appellant relied on In re Bonfield, 2002-Ohio-6660, but the court found the case did not support the specific standing arguments appellant advanced.

Sanction teardown · CA Ohio, USA · 2025-11-25

In re T.F., P.F., and S.S. Minor Children

What happened

In CA Ohio, 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)

Appellant cited "Sain v. Roo, 2018-Ohio-2878, ¶ 19," which the court found to be fictitious (no case assigned to that citation).
Fabricated (Case Law)

Appellant cited "In re Whitaker, 36 Ohio App.3d 213 (1987)," but the court found this citation to be incorrect/fictitious (36 Ohio App.3d 213 is State v. Arvanitis).
Fabricated (Case Law)

Appellant relied on "In re M.M., 2015-Ohio-2571" and another similar citation, which the court identified as fictitious/misassigned and not supporting appellant's propositions.
False Quotes (Case Law)

Appellant attributed a quotation to Braatz v. Braatz, 85 Ohio St.3d 40 (1999), but the court found the quoted language does not appear in Braatz.
Fabricated (Case Law)

Appellant cited "In re K.W., 2016-Ohio-5272, ¶ 16," which the court determined was mis-cited / assigned to a different case and did not support his claim.
Fabricated (Case Law)

Appellant cited "In re J.J., 2017-Ohio-5467, ¶ 29," but the court noted no case is assigned to that citation.
Misrepresented (Case Law)

Appellant referenced "State v. Smith, 2022-Ohio-1234," but the court observed that citation is assigned to a different case (In re Z.L.) and does not support appellant's asserted proposition.
Misrepresented (Case Law)

Appellant cited "In re G.C., 2020-Ohio-4092" for legal propositions, but the court found that citation is assigned to an unrelated case (Oregon v. Gaughan) and does not support his claims.
False Quotes (Case Law)

Appellant attributed a quotation/supportive language to In re Guardianship of Hollins, 114 Ohio St.3d 434 (2007), but the court found no such quotation in Hollins.
Misrepresented (Case Law)

Appellant relied on In re Bonfield, 2002-Ohio-6660, but the court found the case did not support the specific standing arguments appellant advanced.

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1153/In_re_TF_PF_and_SS_Minor_Children_USA_25_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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