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Lonnie Allbaugh v. University of Scranton

Court
M.D. Pennsylvania
Jurisdiction
USA
Decided
2025-08-28
AI tool
Unidentified
Outcome
Monetary sanction; complaint dismissed without prejudice; leave to amend granted.
Monetary penalty
1000 USD

What was hallucinated

Fabricated: Case Law | Quoted language allegedly from the cited case—"We do not require a plaintiff to plead a prima facie case of discrimination to survive a motion to dismiss."—which does not appear in the actual case plaintiff said he meant || Fabricated: Case Law | Submitted a non-existent Third Circuit case as authority; opposing party and court could not locate the opinion and plaintiff later admitted the citation was AI-generated.

Details

The court later declined to reconsider its sanction (see here).

Sanction teardown · M.D. Pennsylvania, USA · 2025-08-28

Lonnie Allbaugh v. University of Scranton

What happened

In M.D. Pennsylvania, 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)
    Quoted language allegedly from the cited case—"We do not require a plaintiff to plead a prima facie case of discrimination to survive a motion to dismiss."—which does not appear in the actual case plaintiff said he meant
  • Fabricated (Case Law)
    Submitted a non-existent Third Circuit case as authority; opposing party and court could not locate the opinion and plaintiff later admitted the citation was AI-generated.

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; complaint dismissed without prejudice; leave to amend granted. (monetary penalty: 1000 USD.)

Additional detail

The court later declined to reconsider its sanction (see here).

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/728/Allbaugh_v._Scranton_Uni_USA_28_August_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/728/Allbaugh_v._Scranton_Uni_USA_28_August_2025.pdf

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