What was hallucinated

Fabricated: Case Law | Motion to Compel (D0143) cited a nonexistent case 'Midwest Recovery Servs. v. Cooperatives Ins. Co., 785 N.W.2d 169 (Iowa Ct. App. 2010)'; court could not locate citation and concluded it was likely manufactured. || Fabricated: Case Law | Motion to Gain Access to Documents (D0143) cited 'Hickman v. Sacred Heart Corp., 653 N.W.2d 522 (Iowa 2002)', which the court could not locate and appears to be an AI-created mis-citation possibly conflating State v. Watson decisions. || Fabricated: Case Law | Motion to Dismiss (D0150) cited 'Kellogg v. Iowa State Bank of Wapello, 189 N.W.2d 354 (Iowa 1971)', a misattributed citation (actual reporter reference tied to an unrelated Michigan case) and not relevant to the issues asserted. || Fabricated: Case Law | Resistance (D0164) cited 'Niemann v. Breen, 641 N.W.2d 146 (Iowa Ct. App. 2002)', which the court found does not exist and corresponds to a South Dakota case instead; cited to support pro se leniency. || Fabricated: Case Law | Plaintiff identified approximately ten additional instances across York's filings where cases or citations were nonexistent or did not support the propositions attributed to them.

Sanction teardown · D. Iowa, USA · 2025-01-02

Postma v. York

What happened

In D. Iowa, 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)

Motion to Compel (D0143) cited a nonexistent case 'Midwest Recovery Servs. v. Cooperatives Ins. Co., 785 N.W.2d 169 (Iowa Ct. App. 2010)'; court could not locate citation and concluded it was likely manufactured.
Fabricated (Case Law)

Motion to Gain Access to Documents (D0143) cited 'Hickman v. Sacred Heart Corp., 653 N.W.2d 522 (Iowa 2002)', which the court could not locate and appears to be an AI-created mis-citation possibly conflating State v. Watson decisions.
Fabricated (Case Law)

Motion to Dismiss (D0150) cited 'Kellogg v. Iowa State Bank of Wapello, 189 N.W.2d 354 (Iowa 1971)', a misattributed citation (actual reporter reference tied to an unrelated Michigan case) and not relevant to the issues asserted.
Fabricated (Case Law)

Resistance (D0164) cited 'Niemann v. Breen, 641 N.W.2d 146 (Iowa Ct. App. 2002)', which the court found does not exist and corresponds to a South Dakota case instead; cited to support pro se leniency.
Fabricated (Case Law)

Plaintiff identified approximately ten additional instances across York's filings where cases or citations were nonexistent or did not support the propositions attributed to them.

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; 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/2363/36_-_Postma_v_York.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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