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Xavier Jamal Smith v. Santander Consumer USA Inc.

Court
N.D. Indiana
Jurisdiction
USA
Decided
2025-11-04
AI tool
Implied
Outcome
—
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Citizens Nat’l Bank of Paris v. Midwest Agri-Dev. Corp., 887 F.2d 1128, 1134 (7th Cir. 1989)'; the Court found the reporter citation corresponds to an unrelated First Circuit opinion, no Seventh Circuit case by that name from 1989 appears to exist, and it could not locate any case containing the quoted language.

Details

Rather amazingly, plaintiff asked and was granted leave to file a "Case Law Verification Index" that contained further hallucinations.

Sanction teardown · N.D. Indiana, USA · 2025-11-04

Xavier Jamal Smith v. Santander Consumer USA Inc.

What happened

In N.D. Indiana, 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)
    Plaintiff cited 'Citizens Nat’l Bank of Paris v. Midwest Agri-Dev. Corp., 887 F.2d 1128, 1134 (7th Cir. 1989)'; the Court found the reporter citation corresponds to an unrelated First Circuit opinion, no Seventh Circuit case by that name from 1989 appears to exist, and it could not locate any case containing the quoted language.

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

Not specified in source record.

Additional detail

Rather amazingly, plaintiff asked and was granted leave to file a "Case Law Verification Index" that contained further hallucinations.

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/1060/Smith_v._Santander_USA_4_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1060/Smith_v._Santander_USA_4_November_2025.pdf

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