What was hallucinated

Misrepresented: Case Law | Plaintiff cited Sierra Club v. Franklin County Power of Illinois, LLC, 546 F.3d 918 (7th Cir. 2008) to support that required fixes are modest in cost, but Sierra Club addresses environmental injunctive relief and is unrelated to website accessibility costs. || Fabricated: Case Law | Citations in paragraphs 18–19 could not be located on Lexis or Westlaw and were treated as fabricated by the Court. || Misrepresented: Case Law | Plaintiff cited Liebhart v. SPX Corp., 998 F.3d 772 (7th Cir. 2021) for a four-factor injunction test that the Court found the motion misstates. || Misrepresented: Case Law | Plaintiff cited Goodman v. Illinois Dep't of Financial & Professional Regulation, 430 F.3d 432 (7th Cir. 2005) as authority that the ADA does not provide compensatory or punitive damages, but Goodman concerns a First Amendment challenge and does not address the ADA.

Sanction teardown · C.D. Illinois, USA · 2026-07-24

Morgan Cole v. Hobby Town Unlimited, Inc.

What happened

In C.D. Illinois, 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 Sierra Club v. Franklin County Power of Illinois, LLC, 546 F.3d 918 (7th Cir. 2008) to support that required fixes are modest in cost, but Sierra Club addresses environmental injunctive relief and is unrelated to website accessibility costs.
Fabricated (Case Law)

Citations in paragraphs 18–19 could not be located on Lexis or Westlaw and were treated as fabricated by the Court.
Misrepresented (Case Law)

Plaintiff cited Liebhart v. SPX Corp., 998 F.3d 772 (7th Cir. 2021) for a four-factor injunction test that the Court found the motion misstates.
Misrepresented (Case Law)

Plaintiff cited Goodman v. Illinois Dep't of Financial & Professional Regulation, 430 F.3d 432 (7th Cir. 2005) as authority that the ADA does not provide compensatory or punitive damages, but Goodman concerns a First Amendment challenge and does not address the ADA.

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

Order to Show Cause

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/2703/Cole_v._Hobby_Town_USA_24_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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