Sanction teardown · W.D. Michigan, USA · 2025-08-29

Lothamer Tax Resolution, Inc. v. Paul Kimmel (1)

What happened

In W.D. Michigan, 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)
  Court determined the citation to Baker Hughes Inc. v. S&S Chem., LLC (No. 2:21-cv-2611, 2022 WL 1591563) could not be located at the provided citation and treated it as a fictitious authority.
• Misrepresented (Case Law)
  Court concluded Kimmel mischaracterized or quoted inaccurately from Shane Grp. v. Blue Cross (825 F.3d 299, 305 (6th Cir. 2016)), citing language not found in the decision.
• Fabricated (Case Law)
  Court noted the citation to Hall v. Hall, 584 U.S. 147 (2018) was cited at a location that could not be verified and flagged it among other suspect citations.
• False Quotes (Case Law)
  Court observed that language Kimmel attributes to FormFactor, Inc. v. Micro-Probe, Inc. (No. 10-3095, 2012 WL 2061520) does not appear in that opinion, i.e., a false quotation/misattribution.
• Fabricated (Case Law)
  Court found the cited PFK Co. v. Protective Technologies, Inc., 624 F. Supp. 2d 802 (S.D. Ind. 2008) could not be located at the provided citation and treated it as a fabricated authority.

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/748/Lothamer_Tax_Resolution_v._Kimmel_USA_29_August_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).