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Martin v. Hawai'i

Court
D. Hawaii
Jurisdiction
USA
Decided
2024-08-20
AI tool
Unidentified
Outcome
Warning, and Order to file further submissions with Declaration
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Petitioner cited Huffman v. Bright, 636 F. Supp. 133 (D. Colo. 1986); the Court stated this citation is not accurate and appears fictitious. || Misrepresented: Legal Norm | Petitioner asserted that removal statutes should be construed generously to protect federal rights; the Court held the Ninth Circuit requires strict construction and resolves doubts against removal. || Misrepresented: Legal Norm | Petitioner claimed an evidentiary hearing was required before remand; the Court explained § 1455(4)-(5) permits summary remand when facially deficient. || False Quotes: Case Law | Petitioner quoted Morford for an equal-protection rule about unavailability of an impartial judge; the Court said the quotation appears fictitious and the citation is not accurate. || Fabricated: Case Law | Petitioner cited Crenshaw v. City of Defuniak Springs, 891 F.3d 1338 (11th Cir. 2018); the Court stated this citation is not accurate and appears fictitious. || False Quotes: Case Law | Petitioner quoted Holley for a liberal-construction rule on removal deadlines; the Court said the quotation appears fictitious and the citation is not accurate.

Sanction teardown · D. Hawaii, USA · 2024-08-20

Martin v. Hawai'i

What happened

In D. Hawaii, 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)
    Petitioner cited Huffman v. Bright, 636 F. Supp. 133 (D. Colo. 1986); the Court stated this citation is not accurate and appears fictitious.
  • Misrepresented (Legal Norm)
    Petitioner asserted that removal statutes should be construed generously to protect federal rights; the Court held the Ninth Circuit requires strict construction and resolves doubts against removal.
  • Misrepresented (Legal Norm)
    Petitioner claimed an evidentiary hearing was required before remand; the Court explained § 1455(4)-(5) permits summary remand when facially deficient.
  • False Quotes (Case Law)
    Petitioner quoted Morford for an equal-protection rule about unavailability of an impartial judge; the Court said the quotation appears fictitious and the citation is not accurate.
  • Fabricated (Case Law)
    Petitioner cited Crenshaw v. City of Defuniak Springs, 891 F.3d 1338 (11th Cir. 2018); the Court stated this citation is not accurate and appears fictitious.
  • False Quotes (Case Law)
    Petitioner quoted Holley for a liberal-construction rule on removal deadlines; the Court said the quotation appears fictitious and the citation is not accurate.

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, and Order to file further submissions with Declaration

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/353/Martin_v._Hawai_D._Hawai_USA_August_20_2024.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/353/Martin_v._Hawai_D._Hawai_USA_August_20_2024.pdf

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