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Woodrow Jackson v. Auto-Owners Insurance Company

Court
M.D. Georgia
Jurisdiction
USA
Decided
2025-07-14
AI tool
Unidentified
Outcome
Monetary sanction; CLE requirement; Adverse Costs Order
Monetary penalty
1000 USD

What was hallucinated

Fabricated: Case Law | Non-existent case citation 1 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 2 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 3 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 4 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 5 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 6 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 7 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 8 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case. || Fabricated: Case Law | Non-existent case citation 9 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.

Details

Plaintiff's Counsel cited nine non-existent cases in a response to a motion to dismiss, which were generated using AI software. The court found this to be a violation of Rule 11, as the citations were not checked for accuracy. Counsel admitted the error, apologized, and explained the circumstances, including staff transitions and the use of AI. The court imposed a $1000 sanction, required Mr. Braddy to attend a CLE course on AI ethics, and ordered reimbursement of Defendant's attorney fees and costs.

Sanction teardown · M.D. Georgia, USA · 2025-07-14

Woodrow Jackson v. Auto-Owners Insurance Company

What happened

In M.D. Georgia, 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)
    Non-existent case citation 1 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 2 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 3 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 4 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 5 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 6 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 7 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 8 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.
  • Fabricated (Case Law)
    Non-existent case citation 9 of 9 in Plaintiff’s MTD Response; neither the Court nor opposing counsel could locate it; Court deemed it a hallucinated case.

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; CLE requirement; Adverse Costs Order (monetary penalty: 1000 USD.)

Additional detail

Plaintiff's Counsel cited nine non-existent cases in a response to a motion to dismiss, which were generated using AI software. The court found this to be a violation of Rule 11, as the citations were not checked for accuracy. Counsel admitted the error, apologized, and explained the circumstances, including staff transitions and the use of AI. The court imposed a $1000 sanction, required Mr. Braddy to attend a CLE course on AI ethics, and ordered reimbursement of Defendant's attorney fees and costs.

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/593/JACKSON_v._AUTO_OWNERS_INSURANCE_COMPANY_USA_14_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/593/JACKSON_v._AUTO_OWNERS_INSURANCE_COMPANY_USA_14_July_2025.pdf

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