Sanction teardown · CA Georgia, USA · 2025-06-30
Shahid v. Esaam
What happened
In CA Georgia, 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)Trial court's order relied on a fictitious case labeled 'Epps'; appellate court could not locate it and vacated the order.
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Fabricated (Case Law)Trial court's order relied on a fictitious case labeled 'Hodge'; appellate court could not locate it and vacated the order.
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Fabricated (Case Law)Appellee's Brief cited a non-existent case; court listed it as fictitious.
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Fabricated (Case Law)Appellee's Brief cited a non-existent 'Miller v. Miller' with a mismatched parallel cite; court found the reporter cite corresponds to an unrelated criminal case.
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Fabricated (Case Law)Appellee's Brief cited a non-existent divorce case; court listed it as fictitious.
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Fabricated (Case Law)Appellee's Brief cited a non-existent case styled against the State; court listed it as fictitious.
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Fabricated (Case Law)Appellee's Brief cited a non-existent Ramos decision; court listed it as fictitious.
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Fabricated (Case Law)Appellee's Brief cited a non-existent McRae decision; court listed it as fictitious.
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Fabricated (Case Law)Appellee's Brief cited a non-existent Johnson decision to support attorney fees on appeal; court could not find it.
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Fabricated (Case Law)Husband's Response cited a non-existent case; court listed it as fictitious.
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Fabricated (Case Law)Husband's Response cited a non-existent Christie decision; court listed it as fictitious.
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Fabricated (Case Law)Husband's Response cited a non-existent Mobley decision; court listed it as fictitious.
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Misrepresented (Case Law)Appellee's Brief misrepresented Blasingame as supporting service by publication; court said the case had nothing to do with service by publication.
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Misrepresented (Case Law)Appellee's Brief misrepresented Wilson as governing deference to trial court factual findings; court noted Wilson says nothing about that standard of review.
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Misrepresented (Case Law)Appellee's Brief misrepresented Brown v. Tomlinson as establishing deference in absence of a transcript; court said the case says nothing about that.
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Misrepresented (Case Law)Appellee's Brief misrepresented Jones v. State as requiring affirmance without a transcript; court noted the case had a transcript and said nothing related to that proposition.
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Misrepresented (Legal Norm)Appellee's Brief asserted OCGA § 9-15-14 authorizes attorney's fees on appeal; court explained longstanding law holds appellate fees are not recoverable under this statute.
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Fabricated (Case Law)Husband's Response cited a non-existent Robinson decision; court listed it as fictitious.
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Fabricated (Case Law)Husband's Response cited a non-existent Reynolds decision (distinct from the real 2015 Supreme Court case); court listed it as fictitious.
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
Case remanded; monetary penalty (monetary penalty: 2500 USD.)
Additional detail
" After the trial court entered a final judgment and decree of divorce, Nimat Shahid (“Wife”) filed a petition to reopen the case and set aside the final judgment, arguing that service by publication was improper. The trial court denied the motion, using an order that relied upon non-existent case law.""We are troubled by the citation of bogus cases in the trial court's order. As the reviewing court, we make no findings of fact as to how this impropriety occurred, observing only that the order purports to have been prepared by Husband's attorney, Diana Lynch. We further note that Lynch had cited the two fictitious cases that made it into the trial court's order in Husband's response to the petition to reopen, and she cited additional fake cases both in that Response and in the Appellee's Brief filed in this Court. "
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/530/Shahid_v._Esaam_Georgia_30_June_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).