What was hallucinated

Fabricated: Case Law | Cited 'Hazy v. Ford Motor Co., 2021 WL 2345678'—the court found this case does not exist. || Fabricated: Case Law | Cited 'Canal Ins. Co. v. Coleman, 625 So. 2d 297 (Miss. 1993)'—court found the citation incorrect; a Canal Ins. Co. opinion exists but is 625 F.3d 244 (5th Cir. 2010) and is not about claims-manual discovery. || Misrepresented: Case Law | Cited Levens v. Campbell; Johnson v. Preferred Risk Auto. Ins. Co.; Dunn v. State Farm—these authorities exist but were cited as establishing that claims manuals are always discoverable; the court found they do not stand for that proposition (misstated precedent). || Fabricated: Case Law | Cited 'Patterson v. Allstate, 2019 WL 1239855 (S.D. Miss. 2019)'—court/defendant could not locate the case and the Westlaw cite corresponds to an unrelated FLSA case (Holt). || Misrepresented: Case Law | Cited 'Architex Ass'n v. Scottsdale Ins., 2022 WL 1234567'—the citation is fictional; the actual case is Architex Ass'n, Inc. v. Scottsdale Ins. Co., 27 So. 3d 1148 (Miss. 2010), which does not address claims-manual discovery as plaintiff claimed.

Sanction teardown · S.D. Mississippi, USA · 2025-09-17

Latasha Hill v. Auto Club Family Insurance Company

What happened

In S.D. Mississippi, 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)

Cited 'Hazy v. Ford Motor Co., 2021 WL 2345678'—the court found this case does not exist.
Fabricated (Case Law)

Cited 'Canal Ins. Co. v. Coleman, 625 So. 2d 297 (Miss. 1993)'—court found the citation incorrect; a Canal Ins. Co. opinion exists but is 625 F.3d 244 (5th Cir. 2010) and is not about claims-manual discovery.
Misrepresented (Case Law)

Cited Levens v. Campbell; Johnson v. Preferred Risk Auto. Ins. Co.; Dunn v. State Farm—these authorities exist but were cited as establishing that claims manuals are always discoverable; the court found they do not stand for that proposition (misstated precedent).
Fabricated (Case Law)

Cited 'Patterson v. Allstate, 2019 WL 1239855 (S.D. Miss. 2019)'—court/defendant could not locate the case and the Westlaw cite corresponds to an unrelated FLSA case (Holt).
Misrepresented (Case Law)

Cited 'Architex Ass'n v. Scottsdale Ins., 2022 WL 1234567'—the citation is fictional; the actual case is Architex Ass'n, Inc. v. Scottsdale Ins. Co., 27 So. 3d 1148 (Miss. 2010), which does not address claims-manual discovery as plaintiff claimed.

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

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/802/LATASHA_HILL_PLAINTIFF_v_AUTO_CLUB_FAMILY_INSURANCE_COMPANY_DEFENDANT.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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