Sanction teardown · M.D. Florida, USA · 2025-09-11

USA v. Brewer

What happened

In M.D. Florida, 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:

• Outdated Advice (Overturned Case Law)
  United States v. Mmahat was cited for broad discoverability of probation files but the decision was abrogated and unrelated to revocation proceedings; subsequent history not cited.
• False Quotes (Case Law)
  Quoted language attributed to United States v. Frazier does not appear in that decision and the case is unrelated to supervised release.
• False Quotes (Case Law)
  Brady quotation omitted the words "upon request," altering its meaning.
• False Quotes (Case Law)
  Quoted language attributed to United States v. Hasting does not appear in the opinion (similar language appears only in a concurrence).
• Misrepresented (Case Law)
  United States v. Bundy was cited for authority to order discovery beyond Rule 32.1, but the cited opinion does not address Rule 32.1, probation, or supervised release.
• Misrepresented (Case Law)
  United States v. Price cited for a proposition about phone records, but the decision does not concern telephone records.
• Fabricated (Case Law)
  United States v. Noel (708 F.3d 245, 254 (1st Cir. 2013)) is entirely fabricated and does not exist as cited.
• False Quotes (Case Law)
  Quoted sentence attributed to United States v. Safavian does not appear in that opinion.
• Misrepresented (Case Law)
  United States v. Siddiqui does not support the proposition that computer audit logs are discoverable for timing/access; the citation was misused.
• Fabricated (Case Law)
  United States v. Hernandez (183 F. Supp. 3d 468, 480 (S.D.N.Y. 2016)) is entirely fabricated according to the court.

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

Show Cause Order

Additional detail

The court found nearly every citation in counsel's motion to be incomplete, inaccurate, or fabricated, describing the references as typical of AI hallucinations and ordering counsel to show cause why sanctions should not be imposed.

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/786/UNITED_STATES_OF_AMERICA_v_BRYAN_L_BREWER.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).