Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided October 2, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · CA Kentucky, USA · 2026-10-02

Grobler v. Kentucky Housing Corporation

What happened

In CA Kentucky, 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 brief cited a nonexistent Kentucky appellate decision as legal authority. The court stated that a simple Google search would show that the case does not exist.
Fabricated (Case Law)

The brief cited a nonexistent Kentucky appellate decision as legal authority. The court stated that a simple Google search would show that the case does not exist.
Fabricated (Case Law)

The brief cited a nonexistent Kentucky appellate decision as legal authority. The court stated that a simple Google search would show that the case does not exist.
Misrepresented (Case Law)

The brief cited real cases but several did not support the legal propositions for which they were cited. The court did not identify each misrepresented case or proposition individually.

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

Not specified in source record.

Additional detail

The Court of Appeals identified multiple citations in Grobler’s pro se brief as apparently AI-hallucinated, including three nonexistent Kentucky cases: Hunt v. Smith, 670 S.W.2d 248 (Ky. App. 1984), Bargo v. Bargo, 616 S.W.3d 389 (Ky. App. 2020), and Roberts v. Hensley, 422 S.W.3d 727 (Ky. App. 2013). The court also stated that several citations to real cases did not support the propositions for which they were cited. Treating these errors as a substantive violation of the appellate rules, the court limited review to manifest injustice and affirmed the order. The court separately rejected Grobler’s purported IRS Form 1099-C as plainly unauthenticated and not issued by the IRS, but did not identify that document as an AI hallucination.

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/3238/Grobler_v._Kentucky_Housing_Corp_USA_02-10-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).