What was hallucinated

Fabricated: Case Law | The court noted that the party cited fabricated ECLI numbers || Misrepresented: Case Law | The court noted that some of the cited cases pertained to criminal law decisions, not to trade law jurisprudence

Details

" When asked, Dwaard (his lawyer) stated that all this was caused by a problem converting a Word file to PDF. This statement raises questions. The court leaves these questions and the question of whether this violated Article 21 of the Dutch Code of Civil Procedure unanswered, because, on balance, Dwaard did not benefit from the incorrect representation of the facts in the statement of defense. " (Google Translate)

Sanction teardown · Rotterdam D., Netherlands · 2025-08-27

The Boys of Rockanje v. Dwaard

What happened

In Rotterdam D., Netherlands, 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)

The court noted that the party cited fabricated ECLI numbers
Misrepresented (Case Law)

The court noted that some of the cited cases pertained to criminal law decisions, not to trade law jurisprudence

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

Not specified in source record.

Additional detail

" When asked, Dwaard (his lawyer) stated that all this was caused by a problem converting a Word file to PDF. This statement raises questions. The court leaves these questions and the question of whether this violated Article 21 of the Dutch Code of Civil Procedure unanswered, because, on balance, Dwaard did not benefit from the incorrect representation of the facts in the statement of defense. " (Google Translate)

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.cyberlawyer.nl/chatshaming-voor-juristen-4-de-hollandse-hallucinatieadvocate/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).