What was hallucinated

Fabricated: Case Law | Court could not locate the district court opinion cited; counsel admitted the citation was not real and produced by AI. || Fabricated: Case Law | Court could not locate the Nevada decision cited; counsel admitted the cited state-court opinion was not real and was AI-generated. || Fabricated: Doctrinal Work | Court could not locate the practice guide/treatise cited; counsel admitted the reference was not real and generated by AI. || Fabricated: Case Law | Court could not locate the opinion cited; counsel later admitted the cited decision was not real and was AI-generated. || Fabricated: Case Law | Court could not locate the Ninth Circuit opinion cited; counsel admitted the citation was not real and produced by AI.

Sanction teardown · D. Nevada, USA · 2025-12-30

M.T. Real Estate Investment Inc. v. Servis One, Inc., et al.

What happened

In D. Nevada, 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 could not locate the district court opinion cited; counsel admitted the citation was not real and produced by AI.
Fabricated (Case Law)

Court could not locate the Nevada decision cited; counsel admitted the cited state-court opinion was not real and was AI-generated.
Fabricated (Doctrinal Work)

Court could not locate the practice guide/treatise cited; counsel admitted the reference was not real and generated by AI.
Fabricated (Case Law)

Court could not locate the opinion cited; counsel later admitted the cited decision was not real and was AI-generated.
Fabricated (Case Law)

Court could not locate the Ninth Circuit opinion cited; counsel admitted the citation was not real and produced by AI.

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

Briefs Struck; Adverse Costs Order; Bar Referral

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/1234/MT_Real_Estate_v._Servus_One_USA_30_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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