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OLG Celle, 5 U 1/25

Court
OLG Celle
Jurisdiction
Germany
Decided
2025-04-29
AI tool
Implied
Outcome
The court identified the cited authorities as unverifiable 'Fehlzitate' and declined to rely on them; no professional sanction or monetary penalty was imposed.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Defendant cited an OLG München decision (12.11.2015, 23 U 2003/15, NJW-RR 2016, 328); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat. || Fabricated: Case Law | Defendant cited an OLG Frankfurt decision (30.05.2018, 4 U 257/17, BeckRS 2018, 15994); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat. || Fabricated: Case Law | Defendant cited an OLG Düsseldorf decision (13.04.2017, I-6 U 271/16, BeckRS 2017, 112233); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat. || Fabricated: Case Law | Defendant cited an OLG Koblenz decision (15.10.2020, 6 U 1261/19); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat.

Details

The defendant's briefs contained multiple case citations that the court determined were 'Fehlzitate' (unverifiable) because they could not be found in juris or beck-online under the given parameters. The court flagged these fabricated citations, refused to rely on them, and based its legal assessment on other verified authorities and the parties' factual pleadings. No professional sanctions or fines were imposed.

Sanction teardown · OLG Celle, Germany · 2025-04-29

OLG Celle, 5 U 1/25

What happened

In OLG Celle, Germany, 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)
    Defendant cited an OLG München decision (12.11.2015, 23 U 2003/15, NJW-RR 2016, 328); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat.
  • Fabricated (Case Law)
    Defendant cited an OLG Frankfurt decision (30.05.2018, 4 U 257/17, BeckRS 2018, 15994); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat.
  • Fabricated (Case Law)
    Defendant cited an OLG Düsseldorf decision (13.04.2017, I-6 U 271/16, BeckRS 2017, 112233); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat.
  • Fabricated (Case Law)
    Defendant cited an OLG Koblenz decision (15.10.2020, 6 U 1261/19); court found the citation unverifiable in juris and beck-online and treated it as a Fehlzitat.

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

The court identified the cited authorities as unverifiable 'Fehlzitate' and declined to rely on them; no professional sanction or monetary penalty was imposed.

Additional detail

The defendant's briefs contained multiple case citations that the court determined were 'Fehlzitate' (unverifiable) because they could not be found in juris or beck-online under the given parameters. The court flagged these fabricated citations, refused to rely on them, and based its legal assessment on other verified authorities and the parties' factual pleadings. No professional sanctions or fines were imposed.

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/2928/55ea1bb2-0c67-4731-8e65-0d75ddb8ad0c_C3aj4xa.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2928/55ea1bb2-0c67-4731-8e65-0d75ddb8ad0c_C3aj4xa.pdf

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