Sanction teardown · CA Federal Circuit, USA · 2025-12-15

Sayali Kulkarni & Abhijit Kulkarni v. Merit Systems Protection Board

What happened

In CA Federal Circuit, 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)
  Reply brief cites “Special Counsel v. Hatch, 654 F.3d 1376, 1382 (Fed. Cir. 2011),” a citation the court identifies as incorrect (reporter citation actually corresponds to CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366 (Fed. Cir. 2011)). Court treated this as a fictitious/misleading citation in the briefing and relied on it as basis to strike the briefs.
• False Quotes (Case Law)
  Reply brief quotes language attributed to Shinseki v. Sanders, 556 U.S. 396, 409 (2009) that the court states does not appear in that opinion (a false quotation attributed to an existing case).

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

Affirmed the Board; granted motions to strike the Kulkarnis' informal reply briefs containing the false citations/quotes

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/1180/ABHIJIT_KULKARNI_v._MSPB_USA_15_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).