Sanction teardown · S.D. Mississippi, USA · 2025-12-30
Pauliah v. University of Mississippi Medical Center
What happened
In S.D. Mississippi, 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:
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False Quotes (Exhibits & Submissions)Fabricated quotation presented as from Dr. Howard's deposition—"He did not receive adequate departmental support... I loaned my laptop so he could complete the report."—attributed to 'Howard Dep. 33:5-34:3'; court found the quote absent from the transcript and fabricated.
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Fabricated (Exhibits & Submissions)Multiple manufactured citations to deposition transcripts accompanying fabricated quotations throughout the sworn declaration; court characterized these as deliberate fabrications undermining the record and struck the entire declaration.
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Fabricated (Exhibits & Submissions)Fabricated quotation presented as from Dr. Howard's deposition—"No accreditation failure was ever cited against Dr. Pauliah"—attributed to 'Howard Dep. 27:1-3'; court found the quote does not appear in the transcript and was fabricated.
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
Monetary Sanction; CLE (monetary penalty: 5000 USD.)
Additional detail
The plaintiff's sworn declaration contained multiple fabricated quotations and manufactured deposition citations. Defendants identified the fabrications in a motion to strike; the court found the declaration filed in bad faith, struck it, and imposed sanctions under Fed. R. Civ. P. 56(h). The plaintiff admitted using generative AI to draft portions and failing to review the declaration; counsel failed to verify the citations despite attending and taking the depositions.
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/1243/Pauliah_v._Uni_Mississippi_USA_30_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).