What was hallucinated

Fabricated: Case Law | Court found the cited STJ RN precedent 'Cerutti, Juan c/ Inmobiliaria Patagonia S.A. s/ Daños y perjuicios' to be nonexistent after exhaustive searches. || Fabricated: Case Law | DMX2 S.A.'s counsel cited six precedents that the court could not locate (three attributed to the STJ RN and three to Civil Chambers); the court determined these citations do not exist. || Fabricated: Case Law | The actora's counsel included twenty jurisprudential citations that the court could not find (eighteen attributed to the STJ RN and two to this Chamber); the court deemed them nonexistent.

Sanction teardown · CA General Roca, Argentina · 2025-09-18

Peugeot Citroen Argentina et al. v. Sumarismo

What happened

In CA General Roca, Argentina, 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)

Court found the cited STJ RN precedent 'Cerutti, Juan c/ Inmobiliaria Patagonia S.A. s/ Daños y perjuicios' to be nonexistent after exhaustive searches.
Fabricated (Case Law)

DMX2 S.A.'s counsel cited six precedents that the court could not locate (three attributed to the STJ RN and three to Civil Chambers); the court determined these citations do not exist.
Fabricated (Case Law)

The actora's counsel included twenty jurisprudential citations that the court could not find (eighteen attributed to the STJ RN and two to this Chamber); the court deemed them nonexistent.

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

Counsel's Work not Counted for Fees; Referral to the Bar

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/1073/0000059690-original-6.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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