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In re: Todd Elliott Koger

Court
W.D. Pennsylvania (Bankruptcy)
Jurisdiction
USA
Decided
2025-09-30
AI tool
Implied
Outcome
One-year filing bar.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Court identified a non-existent case cited by the Kogers—used in their filings to support preclusion/ownership arguments—and noted it appeared fabricated, suggesting AI-generated pleadings and raising Rule 9011 concerns.

Details

The Court observed that several authorities cited in the Kogers' pro se filings do not exist and appeared to be fabricated (noting possible use of AI), warned of Rule 9011 implications, and treated the filings as part of an abusive litigation strategy warranting dismissal and a one-year filing bar.

Sanction teardown · W.D. Pennsylvania (Bankruptcy), USA · 2025-09-30

In re: Todd Elliott Koger

What happened

In W.D. Pennsylvania (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 identified a non-existent case cited by the Kogers—used in their filings to support preclusion/ownership arguments—and noted it appeared fabricated, suggesting AI-generated pleadings and raising Rule 9011 concerns.

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

One-year filing bar.

Additional detail

The Court observed that several authorities cited in the Kogers' pro se filings do not exist and appeared to be fabricated (noting possible use of AI), warned of Rule 9011 implications, and treated the filings as part of an abusive litigation strategy warranting dismissal and a one-year filing bar.

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/860/Elliott_Koger_v._Usoroh_USA_30_September_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/860/Elliott_Koger_v._Usoroh_USA_30_September_2025.pdf

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