Sanction teardown · Vermont SC, USA · 2025-12-18
Robert Lafayette v. Alex Abrami et al
What happened
In Vermont SC, 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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Fabricated (Case Law)Plaintiff admitted including fictitious case citations in his filings; court noted prior warning by another court and ordered him to show cause for sanctions.
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False Quotes (Case Law)Plaintiff admitted including fictitious quotations attributed to case law in his filings; court referenced prior warning and set a show-cause hearing for sanctions.
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Misrepresented (Case Law)Defendants argued the amended complaint continues to use inaccurate case citations.
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
Adverse Costs Order; Pre-Filing Injunction (monetary penalty: 7361 USD.)
Additional detail
Order to show cause is here.
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/1222/Lafayette_v._Abrami_USA_18_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).