Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 15, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · W.D. Pennsylvania, USA · 2026-09-15

Bell v. City of Clairton et al.

What happened

In W.D. Pennsylvania, USA, a filing relied on Lexis AI to help draft legal argument. The court identified the following problems with the citations in that filing:

Misrepresented (Case Law)

The brief cited Cunningham for a proposition concerning relief or liability that the case did not support; the Court noted that Cunningham addressed RESPA's statute of limitations and equitable tolling and did not support the asserted proposition, even in dicta.
Misrepresented (Case Law)

The briefs included six case citations lacking issuing courts, dates, and pinpoint citations, and the Court found that the authorities were not adequately checked to determine whether they supported the propositions presented.
Fabricated (Exhibits & Submissions)

Thirteen purported source citations did not identify or link to legal authorities; each hyperlink directed the reader only to the Lexis homepage, leaving the cited propositions unsupported.
Misrepresented (Legal Norm)

The briefing cited 42 U.S.C. § 1981 even though Plaintiff had not asserted a claim under that statute, reflecting AI-assisted inclusion of an inapplicable legal provision.

Which AI tool

Lexis AI. 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

Four hours of CLE and CM/ECF filing training

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/3125/BELL_v._CITY_OF_CLAIRTON_et_al_USA_15_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).