What was hallucinated

False Quotes: Case Law | A quotation attributed to Ogden v. San Juan Cnty., 32 F.3d 452 (10th Cir. 1994) was presented though the quoted language does not appear in that opinion. || Misrepresented: Case Law | Characterized Gates Rubber as imposing sanctions for failure to supplement discovery; the Court states sanctions there were for intentional destruction of evidence. || Fabricated: Case Law | Relied on a non-existent case, as admitted in a prior filing and noted by the Court. || Fabricated: Case Law | Relied on a non-existent case, as admitted in a prior filing and noted by the Court. || Misrepresented: Case Law | Previously submitted misattributed citation noted by the Court. || Misrepresented: Case Law | Previously submitted misattributed citation noted by the Court. || Fabricated: Case Law | Relied on a non-existent case, as admitted in a prior filing and noted by the Court. || Misrepresented: Case Law | Cited Qualcomm for an attorney’s general duty to ensure clients conduct a comprehensive document search; the Court notes Qualcomm addressed a patent owner’s disclosure duty and litigation misconduct, not a general civil discovery duty. || Misrepresented: Case Law | Cited Qualcomm for the proposition that sanctions serve remedial and deterrent purposes; the Court states Qualcomm does not discuss discovery sanctions. || Misrepresented: Case Law | Described Dominion Video as emphasizing procedural compliance in litigation conduct; the Court explains it was a merits decision on a preliminary injunction and intervention, not a procedural/discovery ruling. || False Quotes: Case Law | Quoted parenthetical attributed to Zubulake that does not appear in the opinion, per the Court.

Details

Original Show Cause Order is here. Court noted that Counsel was still citing fabricated authorities, even though show cause proceedings are ongoing in parallel.

Sanction teardown · D. New Mexico, USA · 2025-09-22

Lipe v. Albuquerque Public Schools (1)

What happened

In D. New Mexico, 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:

False Quotes (Case Law)

A quotation attributed to Ogden v. San Juan Cnty., 32 F.3d 452 (10th Cir. 1994) was presented though the quoted language does not appear in that opinion.
Misrepresented (Case Law)

Characterized Gates Rubber as imposing sanctions for failure to supplement discovery; the Court states sanctions there were for intentional destruction of evidence.
Fabricated (Case Law)

Relied on a non-existent case, as admitted in a prior filing and noted by the Court.
Fabricated (Case Law)

Relied on a non-existent case, as admitted in a prior filing and noted by the Court.
Misrepresented (Case Law)

Previously submitted misattributed citation noted by the Court.
Misrepresented (Case Law)

Previously submitted misattributed citation noted by the Court.
Fabricated (Case Law)

Relied on a non-existent case, as admitted in a prior filing and noted by the Court.
Misrepresented (Case Law)

Cited Qualcomm for an attorney’s general duty to ensure clients conduct a comprehensive document search; the Court notes Qualcomm addressed a patent owner’s disclosure duty and litigation misconduct, not a general civil discovery duty.
Misrepresented (Case Law)

Cited Qualcomm for the proposition that sanctions serve remedial and deterrent purposes; the Court states Qualcomm does not discuss discovery sanctions.
Misrepresented (Case Law)

Described Dominion Video as emphasizing procedural compliance in litigation conduct; the Court explains it was a merits decision on a preliminary injunction and intervention, not a procedural/discovery ruling.
False Quotes (Case Law)

Quoted parenthetical attributed to Zubulake that does not appear in the opinion, per the Court.

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

Monetary sanction; self-report to state bars (monetary penalty: 3000 USD.)

Additional detail

Original Show Cause Order is here. Court noted that Counsel was still citing fabricated authorities, even though show cause proceedings are ongoing in parallel.

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/805/Lipe_v_Albuequerque_Public_Schools.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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