What was hallucinated

False Quotes: Legal Norm | Appellant quoted Tenn. Code Ann. § 66-28-304(a)(4) with language the statute does not contain; the court identified this as an inaccurate statutory quotation. || False Quotes: Case Law | Appellant quoted Myint v. Allstate and Walker v. Sunrise for nominal-damages language the court could not find; the quoted language does not appear in those cases and appears fabricated. || Fabricated: Case Law | Appellant cited Perrin v. Perrin, 514 S.W.2d 426 (Tenn. Ct. App. 1974) in support of a point; the court found the citation fabricated/misplaced (actual reporter at that cite is a different case). || Misrepresented: Other | Portions of the complaint and motion contained apparent AI-generated advisory text and damage calculations (boilerplate legal advice and suggested pleadings), which the court flagged as AI-generated/misleading.

Sanction teardown · CA Tennessee, USA · 2026-02-04

Kenneth Merritt v. American Home Shield

What happened

In CA 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:

False Quotes (Legal Norm)

Appellant quoted Tenn. Code Ann. § 66-28-304(a)(4) with language the statute does not contain; the court identified this as an inaccurate statutory quotation.
False Quotes (Case Law)

Appellant quoted Myint v. Allstate and Walker v. Sunrise for nominal-damages language the court could not find; the quoted language does not appear in those cases and appears fabricated.
Fabricated (Case Law)

Appellant cited Perrin v. Perrin, 514 S.W.2d 426 (Tenn. Ct. App. 1974) in support of a point; the court found the citation fabricated/misplaced (actual reporter at that cite is a different case).
Misrepresented (Other)

Portions of the complaint and motion contained apparent AI-generated advisory text and damage calculations (boilerplate legal advice and suggested pleadings), which the court flagged as AI-generated/misleading.

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

Related issues waived on appeal

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/2769/Kenneth_Merritt_v._American_Home_Shield_USA_3_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template