What was hallucinated

Fabricated: Case Law | Plaintiff cited 'EEOC v. Ironworkers Local 28, 2012 WL 4339035 (S.D.N.Y. 2012)' as supporting authority; court stated the citation was incorrect and not located. || Fabricated: Case Law | Plaintiff cited 'Operating Engineers Local 406 JATC, 271 NLRB 1396 (1984)' to support union liability; court found citation incorrect/non-existent and could not locate the case. || Fabricated: Case Law | Plaintiff cited 'IBEW Local 212 (Cincinnati JATC), 331 NLRB 152 (2000)' to argue JATC liability; court determined the citation was incorrect/non-existent.

Details

See beginning of judgment: "Editor's Note: This decision contains discussion of citation references that are incorrect or do not actually exist. These invalid citations appeared in the original court opinion and have been preserved as written since they are part of the official record. Any links to these invalid citations have been removed."

Sanction teardown · M.D. Tennessee, USA · 2025-11-14

Jeremie Montgomery v. AFL-CIO

What happened

In M.D. Tennessee, 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)

Plaintiff cited 'EEOC v. Ironworkers Local 28, 2012 WL 4339035 (S.D.N.Y. 2012)' as supporting authority; court stated the citation was incorrect and not located.
Fabricated (Case Law)

Plaintiff cited 'Operating Engineers Local 406 JATC, 271 NLRB 1396 (1984)' to support union liability; court found citation incorrect/non-existent and could not locate the case.
Fabricated (Case Law)

Plaintiff cited 'IBEW Local 212 (Cincinnati JATC), 331 NLRB 152 (2000)' to argue JATC liability; court determined the citation was incorrect/non-existent.

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.

Additional detail

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/1037/Montgomery_v._AFL-CIO_USA_14_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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