What was hallucinated

False Quotes: Case Law | Plaintiff quoted the MSPB decision as saying "such claims must be brought in another forum," but the quote does not appear in Strong v. Office of Special Counsel, No. DC-1221-23-0052-W-1, 2023 MSPB LEXIS 106; court independently verified the misquote. || False Quotes: Case Law | Plaintiff attributed two statements to Stovall v. United States that do not appear in that opinion; court noted the statements are not in 71 Fed. Cl. 696 (2006). || Fabricated: Case Law | Plaintiff cited a non-existent case, "Brands v. United States," which the court found to be fabricated. || Fabricated: Case Law | Government identified (and court independently verified) several other non-existent cases cited throughout plaintiff's filings (the government flagged eight such citations).

Sanction teardown · Court of Federal Claims, USA · 2025-11-13

Nathan Strong v. The United States

What happened

In Court of Federal Claims, 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 quoted the MSPB decision as saying "such claims must be brought in another forum," but the quote does not appear in Strong v. Office of Special Counsel, No. DC-1221-23-0052-W-1, 2023 MSPB LEXIS 106; court independently verified the misquote.
False Quotes (Case Law)

Plaintiff attributed two statements to Stovall v. United States that do not appear in that opinion; court noted the statements are not in 71 Fed. Cl. 696 (2006).
Fabricated (Case Law)

Plaintiff cited a non-existent case, "Brands v. United States," which the court found to be fabricated.
Fabricated (Case Law)

Government identified (and court independently verified) several other non-existent cases cited throughout plaintiff's filings (the government flagged eight such citations).

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

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/1016/Strong_v._USA_USA_13_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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