What was hallucinated

Fabricated: Case Law | Plaintiff's counsel filed a Notice of Errata acknowledging 'erroneous citation ... errors' in four briefs caused by the attorney's use of AI; the Court treated arguments supported by incorrect or made-up citations as unsupported and declined to consider the amended briefs on those points. || False Quotes: Case Law | Attorney's use of AI produced incorrect quotations and citation errors in submitted briefs; the Court noted these false quotations/citations and cautioned counsel that such misrepresentations violate professional conduct rules and risk sanctions.

Details

Plaintiff's counsel filed a Notice of Errata admitting that erroneous citation and quotation errors in multiple briefs resulted from the attorney's use of generative AI. The Court refused to consider the amended briefs/errata for purposes of its decision and treated any propositions supported solely by the incorrect or made-up citations as unsupported. The Court declined to impose sanctions but warned the attorney that relying on AI without proper oversight can be sanctionable under the New Jersey Rules of Professional Conduct.

Sanction teardown · D. New Jersey, USA · 2025-09-30

Kertesz v. Colony Tire Corp et al.

What happened

In D. New Jersey, 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's counsel filed a Notice of Errata acknowledging 'erroneous citation ... errors' in four briefs caused by the attorney's use of AI; the Court treated arguments supported by incorrect or made-up citations as unsupported and declined to consider the amended briefs on those points.
False Quotes (Case Law)

Attorney's use of AI produced incorrect quotations and citation errors in submitted briefs; the Court noted these false quotations/citations and cautioned counsel that such misrepresentations violate professional conduct rules and risk sanctions.

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

Warning

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/858/Kertesz_v._Colony_Tire_Corp_USA_30_September_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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