Sanction teardown · CA Illinois, USA · 2026-06-30

P-Three Development, LLC v. Therm Flo, Inc.

What happened

In CA 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:

• False Quotes (Case Law)
  Quoted Canon 2.15(c) language and claims about 'appropriate action' that are not found in the cited disciplinary opinion.
• Fabricated (Case Law)
  Cited as authority for intervention standards but does not exist; court could not locate the opinion.
• Fabricated (Case Law)
  Cited as a First District decision supporting intervention but is fictitious.
• Fabricated (Case Law)
  Cited as a published intervention case but does not exist per the court's research.
• Misrepresented (Case Law)
  Attributed multiple intervention-related holdings and direct quotes that do not appear in the actual opinion.
• Misrepresented (Case Law)
  Quoted as holding intervention principles and reversible error language that are not in the opinion.
• Misrepresented (Case Law)
  Attributed several substantive holdings and quotes about intervention and timeliness that do not appear in the decision.
• False Quotes (Case Law)
  Quoted a proposition that the court found does not appear in the cited criminal decision (false quotation).
• Fabricated (Case Law)
  Included in table of authorities as a 2018 First District opinion that the court could not locate.

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

Brief Struck

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/2512/P-Three_Development_v._Therm_Flo_2026_USA_30_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).