Sanction teardown · S.D. Texas (Bankruptcy), USA · 2025-11-06
Kheir v. Titan Team, The Money Source Inc., and Auction.com
What happened
In S.D. Texas (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:
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Fabricated (Case Law)Plaintiff cited Brasher v. Stewart; Court found no such case and the citation points to an unrelated Sabine Pilot Serv. decision; quoted text not present.
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False Quotes (Case Law)Plaintiff quoted language attributed to Reinagel; Court found the quoted text does not appear in Reinagel and the actual holding differs.
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False Quotes (Case Law)Plaintiff attributed a definitive statement about 'void assignments' to Morlock; Court found the quoted language not present and that Morlock addressed non-borrower standing.
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False Quotes (Case Law)Plaintiff attributed liability language to Miller regarding trustee liability under Tex. Prop. Code §51.007(f); Court found Miller did not contain that language or interpret §51.007(f).
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False Quotes (Case Law)Plaintiff cited Slaughter v. Qualls for a requirement tied to the Texas Property Code; Court noted the Texas Property Code was not enacted until 1984 and the quoted text is not in Slaughter.
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Fabricated (Case Law)Plaintiff cited DTND Sierra Invs., LLC v. BNY Mellon; Court found no such decision at the cited reporter/location and the citation corresponded to unrelated authority; quoted language not found.
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Fabricated (Case Law)Plaintiff cited Gossett v. Fed. Home Loan Mortg. Corp. with a quoted passage; Court found the quoted text not present in the actual Gossett decision and the citation did not support the quoted language.
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
Costs Order; 6 hours CLE on generative AI; provide order to client; Bar referral. (monetary penalty: 1 USD.)
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/978/Kheir_v._Titan_Team_The_Money_Source__Auction.com_USA_4_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).