Sanction teardown · Vermont SC, USA · 2026-01-07

Lafayette v. Winters

What happened

In Vermont SC, 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)
  Brief cited a non-existent decision 'In re Grievance of Bunk, 2007 VT 41' — the Court found this citation fabricated and unrelated.
• Fabricated (Case Law)
  Brief cited a non-existent decision 'Vermont Nat. Tel. Co. v. Dept. of Taxes, 2021 VT 84' — the Court determined this citation was fabricated.
• False Quotes (Case Law)
  Brief cited 'George v. Vermont League of Cities and Towns, 2010 VT 1 ¶ 18' with attributed propositions/quotations not present in the actual decision; Court identified incorrect captioning and misquoted content.
• False Quotes (Case Law)
  Brief cited 'Killington, Ltd. v. State, 172 Vt. 182, 194 (2001)' with inaccurate captioning and attributed propositions not found in the real opinion; Court noted the actual caption is Town of Killington v. State.
• False Quotes (Case Law)
  Brief cited 'Vt. State Colleges Faculty Fed'n v. Vt. State Colleges, 172 Vt. 76, 81 (2001)' and attributed propositions/quotations that do not appear in the cited opinion; Court noted the actual caption is Sarvis v. Vermont State Colleges.

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

Briefs struck

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/2339/12_-_Lafayette_v_Winters.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).