What was hallucinated

False Quotes: Case Law | Plaintiff cited a non-existent passage from a Supreme Court case asserting 'Governments descend to the level of a mere private corporation'; the Court noted the passage does not exist and warned such citations may warrant Rule 11 sanctions. || Misrepresented: Legal Norm | Plaintiff claimed the OAG Child Support Division is a private business separate from the government; the Court held it is a state entity entitled to sovereign immunity. || Misrepresented: Legal Norm | Plaintiff alleged the state court lacked lawful judicial authority and acted as clerks for an executive agency; the Court rejected this and affirmed the court’s authority and immunity. || Misrepresented: Legal Norm | Plaintiff argued 28 U.S.C. § 1691 applies to state courts; the Court held the statute applies only to courts of the United States. || Misrepresented: Legal Norm | Plaintiff characterized wage garnishment for child support as 'executive imprisonment'; the Court held Texas law authorizes garnishment for child support. || Misrepresented: Legal Norm | Plaintiff claimed paying child support is slavery or involuntary servitude; the Court cited authority rejecting this contention. || Misrepresented: Legal Norm | Plaintiff asserted a Seventh Amendment jury-trial right in state child support proceedings; the Court held the Seventh Amendment does not govern state courts. || Misrepresented: Legal Norm | Plaintiff claimed standing to sue under 18 U.S.C. § 241; the Court held the criminal statute provides no private right of action. || Misrepresented: Legal Norm | Plaintiff argued Rooker-Feldman did not apply because the child support hearing was not run by a 'real judge'; the Court held Rooker-Feldman applies and is regularly used in child-support contexts. || Misrepresented: Legal Norm | Plaintiff contended the 326th District Court is contractually bound and subject to suit by citizens; the Court held the court is entitled to sovereign immunity.

Details

In a footnote, the court held: "The Court notes that citing non-existent case law might potentially warrant sanctions under Federal Rules of Civil Procedure 11(b) and 11(c). See Fed. R. Civ. P. 11(b)–(c). Because the plaintiff is pro se and the Court is dismissing this suit, it has determined that a fuller investigation and consideration of potential sanctions is not warranted at this point in time."

Sanction teardown · N.D. Texas, USA · 2024-03-06

Martin v. Taylor County

What happened

In N.D. Texas, 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:

False Quotes (Case Law)

Plaintiff cited a non-existent passage from a Supreme Court case asserting 'Governments descend to the level of a mere private corporation'; the Court noted the passage does not exist and warned such citations may warrant Rule 11 sanctions.
Misrepresented (Legal Norm)

Plaintiff claimed the OAG Child Support Division is a private business separate from the government; the Court held it is a state entity entitled to sovereign immunity.
Misrepresented (Legal Norm)

Plaintiff alleged the state court lacked lawful judicial authority and acted as clerks for an executive agency; the Court rejected this and affirmed the court’s authority and immunity.
Misrepresented (Legal Norm)

Plaintiff argued 28 U.S.C. § 1691 applies to state courts; the Court held the statute applies only to courts of the United States.
Misrepresented (Legal Norm)

Plaintiff characterized wage garnishment for child support as 'executive imprisonment'; the Court held Texas law authorizes garnishment for child support.
Misrepresented (Legal Norm)

Plaintiff claimed paying child support is slavery or involuntary servitude; the Court cited authority rejecting this contention.
Misrepresented (Legal Norm)

Plaintiff asserted a Seventh Amendment jury-trial right in state child support proceedings; the Court held the Seventh Amendment does not govern state courts.
Misrepresented (Legal Norm)

Plaintiff claimed standing to sue under 18 U.S.C. § 241; the Court held the criminal statute provides no private right of action.
Misrepresented (Legal Norm)

Plaintiff argued Rooker-Feldman did not apply because the child support hearing was not run by a 'real judge'; the Court held Rooker-Feldman applies and is regularly used in child-support contexts.
Misrepresented (Legal Norm)

Plaintiff contended the 326th District Court is contractually bound and subject to suit by citizens; the Court held the court is entitled to sovereign immunity.

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

Additional detail

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/372/Martin_v._Taylor_County_N.D._Texas_USA_March_6_2024.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template