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Lee v. R&R Home Care, Inc.

Court
E.D. Louisiana
Jurisdiction
USA
Decided
2025-08-28
AI tool
Google Gemini
Outcome
Monetary sanction; referral
Monetary penalty
1000 USD

What was hallucinated

Fabricated: Case Law | Court identified a fabricated case citation attributed to "Roman Catholic Church of Archdiocese of New Orleans v. Louisiana Health Serv. & Indem. Co., No. 20-1361, 2021 WL 1080684," which does not exist and whose cited Westlaw and docket numbers correspond to unrelated cases. || False Quotes: Case Law | Court found a quoted passage attributed to Hermann Hospital v. MEBA Medical & Benefits Plan (5th Cir.) does not appear in Hermann or any case the court could locate.

Sanction teardown · E.D. Louisiana, USA · 2025-08-28

Lee v. R&R Home Care, Inc.

What happened

In E.D. Louisiana, USA, a filing relied on Google Gemini to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Court identified a fabricated case citation attributed to "Roman Catholic Church of Archdiocese of New Orleans v. Louisiana Health Serv. & Indem. Co., No. 20-1361, 2021 WL 1080684," which does not exist and whose cited Westlaw and docket numbers correspond to unrelated cases.
  • False Quotes (Case Law)
    Court found a quoted passage attributed to Hermann Hospital v. MEBA Medical & Benefits Plan (5th Cir.) does not appear in Hermann or any case the court could locate.

Which AI tool

Google Gemini. 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

Monetary sanction; referral (monetary penalty: 1000 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/780/Lee_v_RAndR_Home_Care_Inc.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/780/Lee_v_RAndR_Home_Care_Inc.pdf

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