What was hallucinated

Misrepresented: Case Law | The requester cited two unidentified Commonwealth Court cases and an unidentified OOR Final Determination for propositions they did not support. The OOR stated that AI may have hallucinated or misrepresented the authorities, but did not determine whether AI was used.

Details

The requester cited two Commonwealth Court cases and an OOR Final Determination in support of reconsideration. The OOR found that none of the citations supported the propositions for which they were cited and noted that it was unclear whether the citations had been generated using AI. The petition was denied because no error of law or abuse of discretion was shown, and the requester was not prejudiced because he could file a new appeal after the County's final response.

Sanction teardown · Pennsylvania OOR, USA · 2025-06-23

Michael Marcavage v. Lackawanna County

What happened

In Pennsylvania OOR, 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)

The requester cited two unidentified Commonwealth Court cases and an unidentified OOR Final Determination for propositions they did not support. The OOR stated that AI may have hallucinated or misrepresented the authorities, but did not determine whether AI was used.

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

Petition for reconsideration denied; no sanction imposed.

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.

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Source: https://www.damiencharlotin.com/documents/3257/Marcavage_v._Lackawanna_County_USA_23-06-2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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