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Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided August 14, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Shelby County Circuit Court, Tenn., USA · 2026-08-14

Davis v. Gopal, Didyuk, and Methodist Healthcare-Memphis Hospitals

What happened

In Shelby County Circuit Court, Tenn., 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 (Legal Norm)
    The memoranda requested costs under a nonexistent Tennessee statute. The motion states that Tennessee Code chapter 20-5 ends at section 20-5-118 and contains no section 20-5-119(c).
  • Fabricated (Legal Norm)
    The Methodist motion relied on a nonexistent subdivision of the health-care-liability pre-suit notice statute.
  • False Quotes (Case Law)
    The Didyuk memorandum attributed a 46-word quotation to Martin, purportedly quoting Stevens, but the motion states that neither opinion contains the passage.
  • False Quotes (Case Law)
    The Didyuk memorandum quoted language attributed to Stevens that does not appear in Stevens; the motion identifies it as a rewritten version of Martin's actual language.
  • False Quotes (Case Law)
    The Methodist memorandum presented a composite quotation as if it were a single passage from Stevens. The motion states that Stevens instead contains separate sentences concerning less-than-perfect compliance, prejudice, and substantial compliance.
  • Misrepresented (Case Law)
    The Methodist memorandum asserted a presumption of prejudice and cited Martin page 335. The motion states that Martin adopted no such presumption and held that prejudice is not a separate analytical element.
  • Fabricated (Case Law)
    The Didyuk memorandum cited “Id. at 559” for Martin, but the motion states that Martin runs only from pages 322 through 347 and has no page 559.
  • Misrepresented (Case Law)
    The Didyuk memorandum attributed to J.A.C. facts that allegedly belong to Roberts v. Prill, involving a plaintiff who intentionally left portions of a HIPAA authorization blank.
  • Fabricated (Case Law)
    The Methodist memorandum cited Foster with the reporter citation belonging to Bray, according to the motion.
  • Misrepresented (Case Law)
    The Methodist memorandum allegedly misidentified the estate name and docket number in a citation to a real case.
  • False Quotes (Case Law)
    Both memoranda allegedly deleted the operative words “to enable defendants” from a quotation of Stevens without indicating the omission with ellipses.
  • False Quotes (Case Law)
    Both memoranda allegedly changed J.A.C.’s quotation from “owed no duty” to “owe no duty.”
  • Misrepresented (Case Law)
    The Methodist memorandum allegedly omitted the portion of Christie stating that the hospital could not be prejudiced because no other records existed, thereby presenting only the portion favorable to defendants.
  • Misrepresented (Legal Norm)
    The Methodist memorandum allegedly placed the 120-day limitations extension in subsection (b), although the motion states that the extension appears in subsection (c).

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

Plaintiff moved for a Rule 11.03(1)(b) order to show cause; no sanction had yet been imposed.

Additional detail

Plaintiff's motion alleges that defense counsel filed motions to dismiss containing nonexistent Tennessee statutes, nonexistent statutory subdivisions, fabricated quotations, invented legal standards, incorrect reporter citations, and facts attributed to the wrong cases. The motion identifies alleged AI-generated or copied errors involving Martin, Stevens, J.A.C., Roberts, Lawson, Foster, Bray, and other authorities. The requested relief was an order requiring the identified attorneys and firms to explain their conduct under oath and attend a hearing under Tennessee Rule of Civil Procedure 11.03(1)(b); the motion expressly reserved any sanctions decision.

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/3011/David_v_6QHOnoF._Gopal_USA_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).