Sanction teardown · Texas CA, USA · 2025-06-12
Rochon Eidsvig & Rochon Hafer v. JGB Collateral
What happened
In Texas CA, 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)First of four non-existent case citations in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
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Fabricated (Case Law)Second non-existent case citation in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
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Fabricated (Case Law)Third non-existent case citation in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
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Fabricated (Case Law)Fourth non-existent case citation in Appellants’ May 16, 2024 brief; Appellee and the Court could not locate it; counsel later conceded nonexistence and the section was deleted in the amended brief.
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
8 mandatory hours of Continuous Legal Education on ethics and AI
Additional detail
"Regardless of whatever resources are used to prepare a party’s brief, every attorney has an ongoing responsibility to review and ensure the accuracy of filings with this and other courts. This includes checking that all case law cited in a brief actually exists and supports the points being made. It is never acceptable to rely on software or technology—no matter how advanced—without reviewing and verifying the information. The use of AI or other technology does not excuse carelessness or failure to follow professional standards.Technology can be helpful, but it cannot replace a lawyer’s judgment, research, or ethical responsibilities. The practice of law changes with the use of new technology, but the core duties of competence and candor remain the same. Lawyers must adapt to new tools without lowering their standards."
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/482/Rochon_Eidsvig__Rochon_Hafer_v._JGB_Collateral_Texas_CA_12_June_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).