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Whitehead v. Moore

Court
CA Missouri
Jurisdiction
USA
Decided
2026-08-04
AI tool
Implied
Outcome
Appeal Dismissed (partly based on AI misuse)
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Appellant's brief contained two citations to cases that do not exist in the reporter cited; court identified them as non-existent. || Fabricated: Case Law | A second non-existent case citation in appellant's brief identified by the court as not appearing in the cited reporter. || Misrepresented: Case Law | Appellant cited an existing case but attributed to it a legal proposition that cannot reasonably be inferred from that case; court characterized this as misrepresenting the holding.

Sanction teardown · CA Missouri, USA · 2026-08-04

Whitehead v. Moore

What happened

In CA Missouri, 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)
    Appellant's brief contained two citations to cases that do not exist in the reporter cited; court identified them as non-existent.
  • Fabricated (Case Law)
    A second non-existent case citation in appellant's brief identified by the court as not appearing in the cited reporter.
  • Misrepresented (Case Law)
    Appellant cited an existing case but attributed to it a legal proposition that cannot reasonably be inferred from that case; court characterized this as misrepresenting the holding.

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

Appeal Dismissed (partly based on AI misuse)

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/2785/Rachel_Whitehead_vs._Zackery_Todd_Moore_Jr._USA_4_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2785/Rachel_Whitehead_vs._Zackery_Todd_Moore_Jr._USA_4_August_2026.pdf

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