What was hallucinated

Misrepresented: Case Law | Plaintiff cited Creekmore v. Food Lion, Inc., asserting it supports a rule about incomplete state-court records invalidating removal; the Court found that Creekmore does not support that proposition and Plaintiff misrepresented its holding. || Fabricated: Case Law | Plaintiff cited 'Cornell v. Precision Valve & Automation, Inc., 2011 WL 1420182 (D.N.M. 2011)' repeatedly; the Court was unable to find the case and concluded it is fictitious. || Fabricated: Case Law | Plaintiff relied on 'Baldwin v. Perdue Farms, Inc., 569 F. Supp. 2d 754 (E.D. Va. 2008)'; the Court could not locate this authority and concluded it is nonexistent. || Misrepresented: Case Law | Plaintiff quoted and over-extended a portion of Getty Oil's footnote and represented it as binding Tenth Circuit law; the Court found this characterization misleading. || Misrepresented: Case Law | Plaintiff attributed a non-existent quoted holding to Cornwall v. Robinson and represented it as Tenth Circuit precedent; the Court noted the quoted language does not appear in Cornwall and the issue was not decided there. || Misrepresented: Case Law | Plaintiff cited several Supreme Court and circuit opinions (e.g., Martin v. Franklin Capital, Carnegie-Mellon, Gibbs, Merrell Dow, Steel Co.) and misapplied or overstated their holdings for the proposition that removal should be invalidated here; the Court found those characterizations misleading.

Sanction teardown · D. New Mexico, USA · 2025-11-05

Lowrey v. City of Rio Rancho et al. (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:

Misrepresented (Case Law)

Plaintiff cited Creekmore v. Food Lion, Inc., asserting it supports a rule about incomplete state-court records invalidating removal; the Court found that Creekmore does not support that proposition and Plaintiff misrepresented its holding.
Fabricated (Case Law)

Plaintiff cited 'Cornell v. Precision Valve & Automation, Inc., 2011 WL 1420182 (D.N.M. 2011)' repeatedly; the Court was unable to find the case and concluded it is fictitious.
Fabricated (Case Law)

Plaintiff relied on 'Baldwin v. Perdue Farms, Inc., 569 F. Supp. 2d 754 (E.D. Va. 2008)'; the Court could not locate this authority and concluded it is nonexistent.
Misrepresented (Case Law)

Plaintiff quoted and over-extended a portion of Getty Oil's footnote and represented it as binding Tenth Circuit law; the Court found this characterization misleading.
Misrepresented (Case Law)

Plaintiff attributed a non-existent quoted holding to Cornwall v. Robinson and represented it as Tenth Circuit precedent; the Court noted the quoted language does not appear in Cornwall and the issue was not decided there.
Misrepresented (Case Law)

Plaintiff cited several Supreme Court and circuit opinions (e.g., Martin v. Franklin Capital, Carnegie-Mellon, Gibbs, Merrell Dow, Steel Co.) and misapplied or overstated their holdings for the proposition that removal should be invalidated here; the Court found those characterizations misleading.

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/991/Lowrey_v._City_of_Rio_Rancho_USA_5_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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