Sanction teardown · 6th Cir. CA, USA · 2026-09-24
Koeberer v. Weir, et al.
What happened
In 6th Cir. CA, 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 Jensen v. Wachovia Bank with a Westlaw number that actually identifies a different Central District of California class-action settlement order.
-
Fabricated (Case Law)The brief cited Johnson v. Wells Fargo Bank with a reporter citation that actually corresponds to a Central District of Illinois Clean Air Act decision; the court found no matching Minnesota decision supporting the citation.
-
Misrepresented (Case Law)The brief claimed that In re Agape Litigation denied motions to dismiss based on banks’ failure to report red-flag transactions, but the case granted dismissal and found no cognizable duty based on alleged Bank Secrecy Act violations.
-
Misrepresented (Case Law)The brief claimed that Brooks recognized consumer claims based on noncompliance with NACHA rules, but the decision never mentions NACHA or its rules.
-
Misrepresented (Case Law)The brief cited Kubala as supporting retention of supplemental jurisdiction based on fairness and statute-of-limitations concerns, but Kubala reversed the exercise of supplemental jurisdiction and did not discuss those propositions.
-
Misrepresented (Case Law)The brief claimed that Gentek held supplemental jurisdiction is favored when federal claims are pending, but the case addressed waiver of a challenge to removal and did not support that proposition.
-
False Quotes (Case Law)The brief included a quotation attributed to Queen City Terminals that does not appear in the cited opinion.
-
False Quotes (Case Law)The brief included a quotation attributed to Carnegie-Mellon University v. Cohill that does not appear in the cited opinion.
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
Warning
Additional detail
Show Cause Order is here.
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/3140/Koeberer_v._Weir_USA_24_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).