Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 9, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · D. Utah, USA · 2026-09-09

Beus Gilbert PLLC v. Brigham Young University et al.

What happened

In D. Utah, USA, a filing relied on ClearBrief, Claude, ChatGPT, and Gemini to help draft legal argument. The court identified the following problems with the citations in that filing:

Misrepresented (Case Law)

Counsel attributed language concerning an egregious-misconduct standard for vacatur to Denver & Rio Grande, but the court found that the case contains none of the terms “egregious” or “misconduct” and does not address that standard.
Misrepresented (Case Law)

Counsel cited Oxford Health Plans for a proposition concerning evident partiality under 9 U.S.C. § 10(a)(2), but the court found that the case addressed the separate ground of whether an arbitrator exceeded its powers under § 10(a)(4).
Misrepresented (Case Law)

Counsel attributed a material-effect or actual-influence requirement for alleged arbitrator bias to Denver & Rio Grande, but the court found that the case does not discuss evident partiality or contain the cited terms or their derivatives.
Fabricated (Case Law)

Counsel cited Scandinavian Reins. Co. v. Employers Reins. Corp., 472 F. App’x 806, but the court found that no such case existed under that name; the citation belonged to Dezhong Tian v. Holder, an immigration appeal.

Which AI tool

ClearBrief, Claude, ChatGPT, and Gemini. 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

Two AI-ethics CLE courses; Monetary Sanctions (monetary penalty: 3000 USD.)

Additional detail

Order to Show Cause is here.

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/3057/Gilbert_v._BYU_USA_9_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).