What was hallucinated

Fabricated: Case Law | Citation to United States v. Baker, 539 F. App’x 937, 943 (11th Cir. 2013) as confirming broad discovery rights; court found the citation as styled does not exist and the volume/page cited corresponds to Williams v. Morahan, not Baker, and does not discuss discovery. || Fabricated: Case Law | Citation to Kelley v. City of Birmingham, 2021 WL 1118031, at *2 (N.D. Ala. Mar. 24, 2021) to avoid delaying a deposition; court and opposing party could find no such federal case—only a 1939 Alabama Court of Appeals traffic case with that style. || Fabricated: Case Law | Citation to Greer v. Warden, FCC Coleman I, 2020 WL 3060362, at *2 (M.D. Fla. June 9, 2020) as rejecting an inmate’s request to delay a deposition; court found no such case exists nor a similar case supporting that proposition. || Fabricated: Case Law | Citation to Wilson v. Jackson, 2006 WL 8438651, at *2 (N.D. Ala. Feb. 27, 2006) for granting a Rule 30(a)(2)(B) motion; court found no such case and that the Westlaw number points to an unrelated maritime case in S.D.W. Va. (Douglas v. Ingram Barge Co.). || Misrepresented: Case Law | Citation to Williams v. Asplundh Tree Expert Co., No. 3:05-cv-479, 2006 WL 3343787, at *4 (M.D. Fla. Nov. 17, 2006) for the rule that general objections are useless; court noted a case with that style exists but not with that citation/proposition combination.

Details

In their Response, Counsel confessed to the use of AI tools in their Response to the OSC.(As recounted by Above the Law, the law firm involved quickly deleted a recent post they made about using AI.)In the Order, the judge prefaced her findings by noting that "Even in cases like this one, where lawyers who cite AI hallucinations accept responsibility and apologize profusely, much damage is done. The opposing party expends resources identifying and exposing the fabrication; the court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished."The court further reasoned that "At the threshold, the court rejects the invitation to consider that actual authorities stand for the proposition that the bogus authorities were offered to support. That is a stroke of pure luck for these lawyers, and one that did not remediate the waste and harm their misconduct wrought. Further, any sanctions discount on this basis would amplify the siren call of unverified AI for lawyers who are already confident in their legal conclusion. This court will have no part of that."It added that: "Likewise, the court rejects the invitation to consider that the involved lawyers and firm have been deeply embarrassed in media reports. For many very good reasons, courts traditionally have not relied on the media to do the difficult work of professional discipline, and this court is not about to start."

Sanction teardown · N.D. Alabama, USA · 2025-07-23

Johnson v. Dunn

What happened

In N.D. Alabama, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Citation to United States v. Baker, 539 F. App’x 937, 943 (11th Cir. 2013) as confirming broad discovery rights; court found the citation as styled does not exist and the volume/page cited corresponds to Williams v. Morahan, not Baker, and does not discuss discovery.
Fabricated (Case Law)

Citation to Kelley v. City of Birmingham, 2021 WL 1118031, at *2 (N.D. Ala. Mar. 24, 2021) to avoid delaying a deposition; court and opposing party could find no such federal case—only a 1939 Alabama Court of Appeals traffic case with that style.
Fabricated (Case Law)

Citation to Greer v. Warden, FCC Coleman I, 2020 WL 3060362, at *2 (M.D. Fla. June 9, 2020) as rejecting an inmate’s request to delay a deposition; court found no such case exists nor a similar case supporting that proposition.
Fabricated (Case Law)

Citation to Wilson v. Jackson, 2006 WL 8438651, at *2 (N.D. Ala. Feb. 27, 2006) for granting a Rule 30(a)(2)(B) motion; court found no such case and that the Westlaw number points to an unrelated maritime case in S.D.W. Va. (Douglas v. Ingram Barge Co.).
Misrepresented (Case Law)

Citation to Williams v. Asplundh Tree Expert Co., No. 3:05-cv-479, 2006 WL 3343787, at *4 (M.D. Fla. Nov. 17, 2006) for the rule that general objections are useless; court noted a case with that style exists but not with that citation/proposition combination.

Which AI tool

ChatGPT. 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

Public reprimand, disqualification from the case, and referral to the Bar

Additional detail

In their Response, Counsel confessed to the use of AI tools in their Response to the OSC.(As recounted by Above the Law, the law firm involved quickly deleted a recent post they made about using AI.)In the Order, the judge prefaced her findings by noting that "Even in cases like this one, where lawyers who cite AI hallucinations accept responsibility and apologize profusely, much damage is done. The opposing party expends resources identifying and exposing the fabrication; the court spends time reviewing materials, holding hearings, deliberating about sanctions, and explaining its ruling; the substance of the case is delayed; and public confidence about the trustworthiness of legal proceedings may be diminished."The court further reasoned that "At the threshold, the court rejects the invitation to consider that actual authorities stand for the proposition that the bogus authorities were offered to support. That is a stroke of pure luck for these lawyers, and one that did not remediate the waste and harm their misconduct wrought. Further, any sanctions discount on this basis would amplify the siren call of unverified AI for lawyers who are already confident in their legal conclusion. This court will have no part of that."It added that: "Likewise, the court rejects the invitation to consider that the involved lawyers and firm have been deeply embarrassed in media reports. For many very good reasons, courts traditionally have not relied on the media to do the difficult work of professional discipline, and this court is not about to start."

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/608/Butler-Snow-Order.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).