What was hallucinated

Fabricated: Case Law | Plaintiff's original pro se motion to remand cited non-existent cases; the Court states it is 'littered with non-existent case law' and notes Defendant's table documenting fictitious citations (Doc. 14 at 5-6). || False Quotes: Case Law | Plaintiff's original pro se motion to remand included quotations that do not appear in the cited authorities; the Court characterizes them as 'falsified quotations.'

Details

The court observed that the original motion to remand filed pro se by the plaintiff contained non-existent case law and falsified quotations. Although the court did not impose sanctions in this instance, it warned that future use of fake legal authority would result in a show cause order, including against the Counsel who later joined the case.

Sanction teardown · S.D. Georgia, USA · 2025-06-27

Sister City Logistics, Inc. v. John Fitzgerald

What happened

In S.D. 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:

Fabricated (Case Law)

Plaintiff's original pro se motion to remand cited non-existent cases; the Court states it is 'littered with non-existent case law' and notes Defendant's table documenting fictitious citations (Doc. 14 at 5-6).
False Quotes (Case Law)

Plaintiff's original pro se motion to remand included quotations that do not appear in the cited authorities; the Court characterizes them as 'falsified quotations.'

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

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/559/Sister_City_Logistics_Inc._v._Fitzgerald_USA_27_June_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template