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

Sanction teardown · N.D. Texas, USA · 2026-08-18

Imperial Reliance, LLC v. HZ Properties & Marketing, LLC

What happened

In N.D. Texas, USA, a filing relied on Westlaw generative AI / premium Westlaw subscription to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    The response named the case as “Tankership Management, Inc. v. M/V Sang Jin,” although citation 747 F.2d 958, 964-65 (5th Cir. 1984) refers to Incas Monterey Printing and Packaging, Ltd. v. M/V Sang Jin. Plaintiffs corrected the case name.
  • False Quotes (Case Law)
    The response presented statements that not all counterclaims qualify and do not lie as compulsory counterclaims under Rule 13(a) as direct quotations, but the language did not appear verbatim in Incas or Plant. The quotation marks were removed.
  • False Quotes (Case Law)
    The response attributed the statement that liberal compulsory-counterclaim standards are not without limits and that courts must assess the requisite logical relationship as a direct quotation to the cited cases. Plaintiffs stated it was only an accurate paraphrase and removed the quotation marks.
  • False Quotes (Case Law)
    The response cited Signum, LLC v. Nature’s Lawn Care and included an inaccurate quotation and paraphrase. Plaintiffs removed the authority from the amended response.
  • False Quotes (Case Law)
    The response included direct quotations attributed to Stripling that did not appear in the cited opinion. Plaintiffs removed the quotation marks and treated the language as unsupported quotations.
  • Fabricated (Case Law)
    The response gave an improperly formatted citation for Amaru Entertainment, Inc. v. Brent. Plaintiffs corrected it to 2023 WL 3575562, No. 3:22-CV-2677-BD (N.D. Tex. 2023).

Which AI tool

Westlaw generative AI / premium Westlaw subscription. 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.

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/3208/Imperial_Reliance_v._HZ_Properties_USA_18-08-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).