What was hallucinated

Fabricated: Case Law | Opposition brief cited a non-existent case as if it were binding authority. || Fabricated: Case Law | Opposition brief cited a non-existent case as if it were binding authority. || Misrepresented: Case Law | Cited Howard Univ. v. Best as supporting elements of fraudulent misrepresentation though that decision did not address such a claim. || Misrepresented: Case Law | Cited Lockhart v. Coastal Int'l Sec., Inc. with a quoted phrase and asserted it supported the wrongful termination theory though Lockhart did not contain the quoted phrasing nor resolve the public policy wrongful termination issue as claimed. || Misrepresented: Case Law | Cited Vega v. Hempstead as recognizing that conditioning employment on immigration barriers can be adverse action, though Vega did not involve immigration issues. || Misrepresented: Case Law | Described Larijani v. Georgetown Univ. as sustaining an IIED claim involving visa/immigration issues though the cited reporter and the actual Larijani decision do not involve such issues. || Misrepresented: Case Law | Cited Bible Way Church for promissory estoppel proposition though no promissory estoppel claim was on appeal in that decision. || Misrepresented: Case Law | Cited Robertson v. District of Columbia as holding that employer conduct must be evaluated in full context to support public policy exceptions, though Robertson did not reach the merits of a wrongful termination public-policy claim as presented. || Misrepresented: Case Law | Cited Myers v. Alutiq as supporting the proposition that employers cannot skirt responsibility for visa-related harm, though Myers did not involve visa or immigration issues. || Misrepresented: Case Law | Cited Rodriguez v. Lab'y Corp. as confirming concealment can support a fraud claim though Rodriguez denied the fraudulent misrepresentation claim and did not hold concealment supported fraud in the manner asserted.

Sanction teardown · D. DC, USA · 2025-12-18

Wanyu Zhang v. National Public Radio, Inc.

What happened

In D. DC, 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)

Opposition brief cited a non-existent case as if it were binding authority.
Fabricated (Case Law)

Opposition brief cited a non-existent case as if it were binding authority.
Misrepresented (Case Law)

Cited Howard Univ. v. Best as supporting elements of fraudulent misrepresentation though that decision did not address such a claim.
Misrepresented (Case Law)

Cited Lockhart v. Coastal Int'l Sec., Inc. with a quoted phrase and asserted it supported the wrongful termination theory though Lockhart did not contain the quoted phrasing nor resolve the public policy wrongful termination issue as claimed.
Misrepresented (Case Law)

Cited Vega v. Hempstead as recognizing that conditioning employment on immigration barriers can be adverse action, though Vega did not involve immigration issues.
Misrepresented (Case Law)

Described Larijani v. Georgetown Univ. as sustaining an IIED claim involving visa/immigration issues though the cited reporter and the actual Larijani decision do not involve such issues.
Misrepresented (Case Law)

Cited Bible Way Church for promissory estoppel proposition though no promissory estoppel claim was on appeal in that decision.
Misrepresented (Case Law)

Cited Robertson v. District of Columbia as holding that employer conduct must be evaluated in full context to support public policy exceptions, though Robertson did not reach the merits of a wrongful termination public-policy claim as presented.
Misrepresented (Case Law)

Cited Myers v. Alutiq as supporting the proposition that employers cannot skirt responsibility for visa-related harm, though Myers did not involve visa or immigration issues.
Misrepresented (Case Law)

Cited Rodriguez v. Lab'y Corp. as confirming concealment can support a fraud claim though Rodriguez denied the fraudulent misrepresentation claim and did not hold concealment supported fraud in the manner asserted.

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

Brief struck; Adverse Costs Order (monetary penalty: 1 USD.)

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/2266/Zhang_v._NPR_USA_18_December_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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