What was hallucinated

Fabricated: Case Law | Defendant cited a State v. Boggess published in 1979 that does not exist; the court found no Supreme Court opinion by that name in 1979 (only a 2004 State v. Boggess exists and does not support her points). || Misrepresented: Case Law | Defendant attributed several legal propositions to Cheek v. Poole that the case does not state; court found Cheek does not support the cited propositions.

Details

Defendant's reply brief contained citations that did not support her arguments and included at least one non-existent case citation; the court concluded these errors suggest use of AI and treated the issues as abandonment under Rule 28(b)(6), dismissing the appeal.

Sanction teardown · CA North Carolina, USA · 2025-09-17

Santree v. Eveangel Hines

What happened

In CA North Carolina, 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)

Defendant cited a State v. Boggess published in 1979 that does not exist; the court found no Supreme Court opinion by that name in 1979 (only a 2004 State v. Boggess exists and does not support her points).
Misrepresented (Case Law)

Defendant attributed several legal propositions to Cheek v. Poole that the case does not state; court found Cheek does not support the cited propositions.

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

Appeal dismissed for lack of genuine argument

Additional detail

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/800/SANTREE_NC_LLC_Plaintiff_v_EVEANGEL_HINES_Defendant.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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