Sanction teardown · CA Arizona (1d), USA · 2026-08-10
WRI Summit REIT LP v. Kuerschner
What happened
In CA Arizona (1d), 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:
-
False Quotes (Case Law)Appellant quoted Burton as containing language about 'manifestly unreasonable, or exercised on untenable grounds, or for untenable reasons,' which the court found does not appear in Burton.
-
False Quotes (Case Law)Appellant attributed a de novo review statement re § 12-350 to Bennett that the cited paragraph does not contain.
-
False Quotes (Case Law)Appellant cited Brown for a due-process rule ('Rulings which prevent a party from presenting evidence strike at the heart of due process') though Brown is a 1998 appellate decision and does not contain that language.
-
Fabricated (Case Law)Appellant cited a case the court could not locate (appears non-existent in Arizona appellate reports).
-
Misrepresented (Case Law)Appellant asserted Takieh reversed a fee sanction for failure to make explicit findings under § 12-350; court found Takieh did not contain that language and in fact affirmed the sanction.
-
Misrepresented (Case Law)Appellant represented Hertz as a published, citable opinion when it is an unpublished memorandum decision and cannot be cited for persuasive value.
-
Misrepresented (Case Law)Appellant cited Starr Pass with incorrect reporter number and date (miscitation).
-
Misrepresented (Legal Norm)Appellant incorrectly asserted a rule-based doctrinal requirement about Rule 201 (judicial notice) that misstated the legal norm.
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
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/2835/Summit_Reit_USA_10_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).