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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 · E.D. Michigan, USA · 2026-09-24

Chirece C. v. Commissioner of Social Security

What happened

In E.D. Michigan, 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)
    A nonexistent Williams case was cited as authority for the proposition that inability to sustain sitting or standing because of medically necessary leg elevation precludes competitive sedentary employment. The cited reference instead concerned Widi v. McNeil from the District of Maine and did not involve Social Security.
  • Misrepresented (Case Law)
    A real case was quoted as holding that an ALJ must evaluate whether a claimant can sustain work activity on a regular and continuing basis, but the court found that Howard did not state that rule at the cited page.
  • Misrepresented (Case Law)
    A real case was cited for the proposition that medically necessary leg elevation preventing sustained sitting or standing precludes competitive sedentary employment, but Wages did not mention leg elevation and did not support that proposition.

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

Monetary Fine (monetary penalty: 500 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/3186/Chirece_C._v._Commissioner_of_Social_Security_USA_24-09-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).