What was hallucinated

Fabricated: Case Law | Plaintiff's Response cited nonexistent cases; the Court reviewed and agreed they do not exist. || False Quotes: Case Law | Plaintiff's Response included direct quotes attributed to legal authorities that could not be located; the Court confirmed they could not be found. || Misrepresented: Case Law | Plaintiff's Response contained inaccurate case citations; the Court agreed they were inaccurate.

Details

"Further, these inaccuracies signal that Plaintiff's counsel may have used AI to assist in the drafting of Plaintiff's Response (or otherwise counsel produced exceptionally sloppy work). In this regard, this Court's Chambers Rules include “Disclosure and Certification Requirements” for use of “Generative Artificial Intelligence” and expressly provide that an attorney or party must disclose in any document to be filed with the Court “that AI was used and the specific AI tool that was used” and to “certify in the document that the person has checked the accuracy of any portion of the document drafted by generative AI, including all citations and legal authority.” See id.6 No such disclosure and certification has been made in this case. The Court's Rules further provide that an attorney will be responsible for the contents of any documents prepared with generative AI, in accordance with Rule 11 of the Federal Rules of Civil Procedure, and that the failure to make the disclosure and certification “may result in the imposition of sanctions.”"

Sanction teardown · W.D. Oklahoma, USA · 2025-07-03

Sharita Hill v. State of Oklahoma

What happened

In W.D. Oklahoma, 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)

Plaintiff's Response cited nonexistent cases; the Court reviewed and agreed they do not exist.
False Quotes (Case Law)

Plaintiff's Response included direct quotes attributed to legal authorities that could not be located; the Court confirmed they could not be found.
Misrepresented (Case Law)

Plaintiff's Response contained inaccurate case citations; the Court agreed they were inaccurate.

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

Warning

Additional detail

"Further, these inaccuracies signal that Plaintiff's counsel may have used AI to assist in the drafting of Plaintiff's Response (or otherwise counsel produced exceptionally sloppy work). In this regard, this Court's Chambers Rules include “Disclosure and Certification Requirements” for use of “Generative Artificial Intelligence” and expressly provide that an attorney or party must disclose in any document to be filed with the Court “that AI was used and the specific AI tool that was used” and to “certify in the document that the person has checked the accuracy of any portion of the document drafted by generative AI, including all citations and legal authority.” See id.6 No such disclosure and certification has been made in this case. The Court's Rules further provide that an attorney will be responsible for the contents of any documents prepared with generative AI, in accordance with Rule 11 of the Federal Rules of Civil Procedure, and that the failure to make the disclosure and certification “may result in the imposition of sanctions.”"

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/555/SHARITA_HILL_v_OKLAHOMA_USA_3_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).