What was hallucinated

Misrepresented: Case Law | Pl.'s Opp'n cited Simpkins for the proposition that courts in this Circuit routinely reject motions based solely on attorney argument; the court found this to be a false proposition of law. || Misrepresented: Case Law | Pl.'s Opp'n cited De Aguilar v. Boeing Co. as affirming authority to condition extensions on mediation; the court found this to be a false proposition of law. || False Quotes: Case Law | Pl.'s Opp'n quoted United States v. Johnson for the notion that dilatory conduct against settlement efforts weighs against continuances; the court found the quotation fabricated. || Fabricated: Case Law | Pl.'s Opp'n cited United States v. Jorgensen, which the court determined does not exist, and paired it with a fabricated quotation. || Misrepresented: Case Law | Pl.'s Opp'n cited Morris v. Slappy for a rule requiring diligent attempts to resolve conflicts before seeking a continuance; the court found this to be a false proposition of law. || Misrepresented: Case Law | Pl.'s Opp'n cited United States v. Burton for the holding that continuances may be denied if circumstances are foreseeable or self-imposed; the court found this to be a false proposition of law. || False Quotes: Case Law | Pl.'s Opp'n quoted Doe v. Exxon Mobil Corp. for the statement that unsworn statements by counsel are not evidence; the court found the quotation fabricated. || False Quotes: Case Law | Pl.'s Opp'n quoted United States v. Poston for a requirement that continuances be supported by a firm basis in the record; the court found the quotation fabricated. || False Quotes: Case Law | Pl.'s Opp'n quoted United States v. Burton for the statement that a scheduling conflict alone is insufficient for a continuance; the court found the quotation fabricated.

Details

Show Cause Order is available here.

Sanction teardown · D. DC, USA · 2025-10-03

Smith v. Athena Construction Group, Inc.

What happened

In D. DC, USA, a filing relied on Grammarly; ProWritingAid to help draft legal argument. The court identified the following problems with the citations in that filing:

Misrepresented (Case Law)

Pl.'s Opp'n cited Simpkins for the proposition that courts in this Circuit routinely reject motions based solely on attorney argument; the court found this to be a false proposition of law.
Misrepresented (Case Law)

Pl.'s Opp'n cited De Aguilar v. Boeing Co. as affirming authority to condition extensions on mediation; the court found this to be a false proposition of law.
False Quotes (Case Law)

Pl.'s Opp'n quoted United States v. Johnson for the notion that dilatory conduct against settlement efforts weighs against continuances; the court found the quotation fabricated.
Fabricated (Case Law)

Pl.'s Opp'n cited United States v. Jorgensen, which the court determined does not exist, and paired it with a fabricated quotation.
Misrepresented (Case Law)

Pl.'s Opp'n cited Morris v. Slappy for a rule requiring diligent attempts to resolve conflicts before seeking a continuance; the court found this to be a false proposition of law.
Misrepresented (Case Law)

Pl.'s Opp'n cited United States v. Burton for the holding that continuances may be denied if circumstances are foreseeable or self-imposed; the court found this to be a false proposition of law.
False Quotes (Case Law)

Pl.'s Opp'n quoted Doe v. Exxon Mobil Corp. for the statement that unsworn statements by counsel are not evidence; the court found the quotation fabricated.
False Quotes (Case Law)

Pl.'s Opp'n quoted United States v. Poston for a requirement that continuances be supported by a firm basis in the record; the court found the quotation fabricated.
False Quotes (Case Law)

Pl.'s Opp'n quoted United States v. Burton for the statement that a scheduling conflict alone is insufficient for a continuance; the court found the quotation fabricated.

Which AI tool

Grammarly; ProWritingAid. 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

Costs Order; Order to notify Bar (monetary penalty: 1 .)

Additional detail

Show Cause Order is available here.

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/850/SMITH_v_ATHENA_CONSTRUCTION_GROUP_INC__dcdce-18-02080__0201.0.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