What was hallucinated

Fabricated: Legal Norm | Plaintiffs relied on a purported quotation from Local Civil Rule 1(c) claiming it "permits flexibility 'in the interest of justice'", but the rule contains no such language and the attribution was inaccurate. || Fabricated: Case Law | Plaintiffs attributed the quotation "factual materials underlying an ERISA determination are discoverable" to Abatie v. Alta Health & Life Ins. Co.; the Court found the quotation does not appear in Abatie and could not be located via Westlaw/Google.

Sanction teardown · W.D. Washington, USA · 2025-11-13

William McNae and Ronda McNae v. ARAG Insurance Company

What happened

In W.D. Washington, 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 (Legal Norm)

Plaintiffs relied on a purported quotation from Local Civil Rule 1(c) claiming it "permits flexibility 'in the interest of justice'", but the rule contains no such language and the attribution was inaccurate.
Fabricated (Case Law)

Plaintiffs attributed the quotation "factual materials underlying an ERISA determination are discoverable" to Abatie v. Alta Health & Life Ins. Co.; the Court found the quotation does not appear in Abatie and could not be located via Westlaw/Google.

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

Filing struck; monetary sanction (monetary penalty: 100 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/1036/MacNae_v._Arag_Insurance_Company_13_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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