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Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 18, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · CA Indiana, USA · 2026-09-18

Englert v. Gateway Crossing Property Owners Association, Inc.

What happened

In CA Indiana, 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)
    The court found that this cited case did not exist and identified its use to support the appellant’s argument concerning authority over his property.
  • Fabricated (Case Law)
    The court found that this cited case did not exist and identified it as one of the primary authorities relied upon in the appellant’s argument.
  • Fabricated (Case Law)
    The court found that this case did not exist and noted that the appellant cited it to support his fraud claim.
  • Misrepresented (Case Law)
    The court stated that the case exists but concerns grounds for shifting attorney’s fees, not restrictions on property, and therefore did not support the appellant’s argument about his deed’s subject-to clause.
  • Fabricated (Case Law)
    The court found that the cited case could not be located and stated that it did not support the proposition for which it was offered.
  • Misrepresented (Case Law)
    The court explained that the cited case could not be found at the stated citation; the actual 2013 Wright v. Miller decision appears at 989 N.E.2d 324 and was issued by the Indiana Supreme Court.
  • Misrepresented (Case Law)
    The court noted that the appellant attributed this case to the Indiana Court of Appeals even though it was an Indiana Supreme Court decision, and that it did not support the proposition asserted.
  • Misrepresented (Case Law)
    The court noted that the appellant incorrectly cited and attributed this case in a proposed order, and that it did not support the proposed findings.
  • Fabricated (Case Law)
    The court found that neither of these cited cases existed and identified them as additional fabricated authorities used in a supplement to the motion to correct error.
  • Fabricated (Case Law)
    The court stated that this case did not exist and that it appeared in a proposed order signed by the trial court.

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

Adverse Costs Order Affirmed (monetary penalty: 23222 .)

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/3121/John_L_Englert_v._Gateway_Crossing_Property_Owners_USA_18_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).