Sanction teardown · W.D. Pennsylvania, USA · 2025-10-06
Thomas Dexter Jakes v. Duane Youngblood
What happened
In W.D. Pennsylvania, 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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False Quotes (Exhibits & Submissions)Fabricated quotation attributed to the Court's April 25, 2025 Memorandum Opinion; Court found no such language in its opinion.
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False Quotes (Case Law)Fabricated quote attributed to Franklin Prescriptions, Inc. v. N.Y. Times Co.; Court found the quoted language does not exist in that opinion as cited.
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False Quotes (Case Law)Fabricated statement attributed to Franklin Prescriptions requiring pleading 'the exact words spoken or published'; Court found no such direct quotation in the cited authority.
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False Quotes (Case Law)Fabricated quotation purporting to be from Blackwell v. Eskin (Pa. Super. Ct. 2007); Court found the quoted language does not exist as presented.
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False Quotes (Case Law)Fabricated attribution claiming the Court 'noted that when the underlying tort collapses, there can be no cause of action for conspiracy' citing Hill v. Cosby; Court found the phrasing was not in the cited source.
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False Quotes (Case Law)Fabricated quotation attributed to Romano v. Young (E.D. Pa. 2011) claiming a specific holding about conspiracy pleadings; Court found the specific quoted language absent from that decision.
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False Quotes (Case Law)Fabricated quotation attributed to Duffy v. Lawyers Title Ins. Co. about group pleading in conspiracy claims; Court determined the quoted passage was not in the cited opinion as presented.
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False Quotes (Case Law)Multiple fabricated or partly fabricated quotations in the reply brief (e.g., Kurowski, Livingston, Moses, St. Amant) that the Court found do not exist in the cited authorities as quoted.
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False Quotes (Case Law)Reply brief quotation claiming Pennsylvania courts 'have shown a willingness to interpret relatively mild statements as being capable of a defamatory meaning' attributed to Livingston v. Murray; Court found the quoted wording was fabricated.
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Misrepresented (Case Law)Misrepresentation: citing cases for propositions they do not support; Court noted multiple instances where Blackbum used cases for propositions the cases do not represent.
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
Monetary Sanction; Pro Hac Vice status revoked (monetary penalty: 5000 USD.)
Additional detail
Original Show Cause Order is 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://reason.com/volokh/2025/06/26/whoever-or-whatever-drafted-the-briefs-signed-and-filed-by-blackburn/?nab=1, via Damien Charlotin's public AI Hallucination Cases Database (CC0).