What was hallucinated

Fabricated: Case Law | Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion. || Misrepresented: Case Law | Counsel cited 'Brown v. Daniel Realty Co., 922 A.2d 1146, 1155–56 (Md. Ct. Spec. App. 2007)' — reporter/pagination matches a Connecticut opinion and the Maryland Brown opinion (949 A.2d 6 (Md. App. 2008)) does not support the proposition cited. || Misrepresented: Case Law | A citation provided by Plaintiffs (reported as Gottfredson) corresponds instead to Brenner v. Heavener, 492 F. Supp. 2d 399 (S.D.N.Y. 2007); Plaintiffs misattributed/substituted a different case and jurisdiction. || Misrepresented: Case Law | Counsel cited Adams v. Rice, 40 F.3d 72 (4th Cir. 1994) as supporting a collateral estoppel point though the opinion addresses IFP dismissal under §1915 and does not discuss collateral estoppel. || False Quotes: Case Law | Counsel placed a parenthetical quote attributed to Jones v. Buchanan, 325 F.3d 520 (4th Cir. 2003) ('a minimal level of force' can violate rights) that does not appear in the opinion; the opinion instead involved substantial force.

Sanction teardown · D. Maryland, USA · 2025-11-17

Neal v. Frayer

What happened

In D. Maryland, 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)

Plaintiffs cited and purported to quote a D. Md. case 'Gottfredson v. Hoyer, 492 F. Supp. 2d 399 (D. Md. 2007)' which the Court could not locate; AI output likewise fabricated detailed content for this nonexistent opinion.
Misrepresented (Case Law)

Counsel cited 'Brown v. Daniel Realty Co., 922 A.2d 1146, 1155–56 (Md. Ct. Spec. App. 2007)' — reporter/pagination matches a Connecticut opinion and the Maryland Brown opinion (949 A.2d 6 (Md. App. 2008)) does not support the proposition cited.
Misrepresented (Case Law)

A citation provided by Plaintiffs (reported as Gottfredson) corresponds instead to Brenner v. Heavener, 492 F. Supp. 2d 399 (S.D.N.Y. 2007); Plaintiffs misattributed/substituted a different case and jurisdiction.
Misrepresented (Case Law)

Counsel cited Adams v. Rice, 40 F.3d 72 (4th Cir. 1994) as supporting a collateral estoppel point though the opinion addresses IFP dismissal under §1915 and does not discuss collateral estoppel.
False Quotes (Case Law)

Counsel placed a parenthetical quote attributed to Jones v. Buchanan, 325 F.3d 520 (4th Cir. 2003) ('a minimal level of force' can violate rights) that does not appear in the opinion; the opinion instead involved substantial force.

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1063/Neal_v._Frayer_USA_17_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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