What was hallucinated

Fabricated: Case Law | Plaintiffs cited 'Dawkins v. Fields, 354 F.3d 392 (5th Cir. 2003)' to support clearly established law; the Court found no such controlling authority and treated the citation as erroneous. || Fabricated: Case Law | Plaintiffs cited 'Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997)'; the Court identified this as a miscitation (likely meant Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008)) and found the cited authority out-of-circuit and inapposite. || Fabricated: Case Law | Plaintiffs relied on 'Yates v. Terry, 817 F.3d 877 (4th Cir. 2016)' to show a clearly established rule for tasing a nonresisting arrestee; the Court treated the citation as non-controlling/out-of-circuit and materially dissimilar to the facts here. || Misrepresented: Case Law | Plaintiffs construed Garner to mean that any application of force against a compliant, non-threatening person is always objectively unreasonable; the Court rejected this overbroad reading as a mischaracterization of Garner.

Sanction teardown · N.D. Texas, USA · 2026-08-27

Peter Williams, et al. v. Dallas-Fort Worth International Airport Board, et al.

What happened

In N.D. Texas, 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 'Dawkins v. Fields, 354 F.3d 392 (5th Cir. 2003)' to support clearly established law; the Court found no such controlling authority and treated the citation as erroneous.
Fabricated (Case Law)

Plaintiffs cited 'Iko v. Shreve, 122 F.3d 707 (4th Cir. 1997)'; the Court identified this as a miscitation (likely meant Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008)) and found the cited authority out-of-circuit and inapposite.
Fabricated (Case Law)

Plaintiffs relied on 'Yates v. Terry, 817 F.3d 877 (4th Cir. 2016)' to show a clearly established rule for tasing a nonresisting arrestee; the Court treated the citation as non-controlling/out-of-circuit and materially dissimilar to the facts here.
Misrepresented (Case Law)

Plaintiffs construed Garner to mean that any application of force against a compliant, non-threatening person is always objectively unreasonable; the Court rejected this overbroad reading as a mischaracterization of Garner.

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

Admonishment & 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/2990/Willia_Fh3WTMr._Dallas-Fort_Worth_International_Airport_Board_et_al_USA_27_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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