What was hallucinated

Fabricated: Case Law | Lancaster cited a nonexistent Sixth Circuit case, which the Court explained was a mutant citation blending a Michigan Supreme Court case with a Fifth Circuit reporter cite. || Fabricated: Case Law | Lancaster cited a case the Court noted does not exist. || Fabricated: Case Law | Lancaster cited a Sixth Circuit case the Court stated does not exist.

Details

AI UseLancaster, filing objections to a magistrate judge’s Report and Recommendation, cited several fabricated case authorities. The Court noted the possibility of reliance on a generative AI tool and explicitly warned Lancaster about future misconduct.Hallucination DetailsFabricated or mutant citations, including:Bazzi v. Sentinel Ins. Co., 961 F.3d 734 (6th Cir. 2020) — mutant citation blending two unrelated real casesMaldonado v. Ford Motor Co., 720 F.3d 760 (5th Cir. 2013) — nonexistentMalliaras & Poulos, P.C. v. City of Center Line, 788 F.3d 876 (6th Cir. 2015) — nonexistentCourt highlighted that the majority of the cited cases in Lancaster’s objections were fake.Ruling/SanctionNo immediate sanction imposed due to pro se status and lack of prior warnings. However, the Court issued a pointed warning that citing "made-up law" could lead to significant sanctions, either in that Court or any other court to which the case might be remanded.Key Judicial ReasoningThe Court emphasized that unverified, fabricated legal citations undermine the judicial process and waste both judicial and litigant resources. Even without clear evidence of malicious intent, negligence in checking citations is sanctionable. Rule 11 duties apply fully to pro se litigants.

Sanction teardown · E.D. Michigan, USA · 2023-09-11

Ruggierlo et al. v. Lancaster

What happened

In E.D. Michigan, 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)

Lancaster cited a nonexistent Sixth Circuit case, which the Court explained was a mutant citation blending a Michigan Supreme Court case with a Fifth Circuit reporter cite.
Fabricated (Case Law)

Lancaster cited a case the Court noted does not exist.
Fabricated (Case Law)

Lancaster cited a Sixth Circuit case the Court stated does not exist.

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

No sanction; Formal Judicial Warning

Additional detail

AI UseLancaster, filing objections to a magistrate judge’s Report and Recommendation, cited several fabricated case authorities. The Court noted the possibility of reliance on a generative AI tool and explicitly warned Lancaster about future misconduct.Hallucination DetailsFabricated or mutant citations, including:Bazzi v. Sentinel Ins. Co., 961 F.3d 734 (6th Cir. 2020) — mutant citation blending two unrelated real casesMaldonado v. Ford Motor Co., 720 F.3d 760 (5th Cir. 2013) — nonexistentMalliaras & Poulos, P.C. v. City of Center Line, 788 F.3d 876 (6th Cir. 2015) — nonexistentCourt highlighted that the majority of the cited cases in Lancaster’s objections were fake.Ruling/SanctionNo immediate sanction imposed due to pro se status and lack of prior warnings. However, the Court issued a pointed warning that citing "made-up law" could lead to significant sanctions, either in that Court or any other court to which the case might be remanded.Key Judicial ReasoningThe Court emphasized that unverified, fabricated legal citations undermine the judicial process and waste both judicial and litigant resources. Even without clear evidence of malicious intent, negligence in checking citations is sanctionable. Rule 11 duties apply fully to pro se litigants.

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/253/Ruggierlo_et_al._v._Lancaster_US_DC_Eastern_Michigan_September_11_2023.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).