Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 24, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · 5th Cir. CA, USA · 2026-09-24

Bourrage v. Sollie

What happened

In 5th Cir. CA, 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)

Bourrage quoted language as coming from Walker v. Epps, but the quoted language does not appear in that opinion.
Misrepresented (Case Law)

Bourrage cited Utterback v. United States as a 2025 Fifth Circuit decision, but no such Fifth Circuit decision exists; the citation corresponds to Fields v. Liberty Healthcare Corp., a 2025 Seventh Circuit case.
Fabricated (Case Law)

Bourrage cited Humphries v. Mississippi Department of Transportation, which the Fifth Circuit could not locate and concluded did not exist.
Fabricated (Case Law)

Bourrage cited State v. Murphy, which the Fifth Circuit could not locate and concluded did not exist.
Misrepresented (Exhibits & Submissions)

Bourrage cited Policy 6517X337 and a Detail Loss Report, but neither document appeared in the record and neither was relevant to the case; the court noted that the documents existed online.

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

Warning

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/3171/Bourrage_v._Sollie_USA_24-09-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).