Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided August 27, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · S.D. Florida, USA · 2026-08-27

Thomas Raynard James v. Detective Kevin Conley, et al.

What happened

In S.D. Florida, 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 (Exhibits & Submissions)

Plaintiff alleged the existence and content of an IACP Training Key that could not be produced or verified and was later conceded to be AI-generated; court found counsel's reliance irresponsible and noted the allegation was AI-hallucinated.
Fabricated (Exhibits & Submissions)

Plaintiff alleged the existence and content of an IACP Training Key that could not be produced or verified and was later conceded to be AI-generated; court found counsel's reliance irresponsible and noted the allegation was AI-hallucinated.
Fabricated (Exhibits & Submissions)

Plaintiff alleged the existence and content of an IACP Training Key that could not be produced or verified and was later conceded to be AI-generated; court found counsel's reliance irresponsible and noted the allegation was AI-hallucinated.
Fabricated (Exhibits & Submissions)

Plaintiff alleged the existence and content of an IACP Training Key that could not be produced or verified and was later conceded to be AI-generated; court found counsel's reliance irresponsible and noted the allegation was AI-hallucinated.
Fabricated (Exhibits & Submissions)

Plaintiff alleged the existence and content of an IACP Training Key that could not be produced or verified and was later conceded to be AI-generated; court found counsel's reliance irresponsible and noted the allegation was AI-hallucinated.

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

Bar Referral

Additional detail

Plaintiff’s counsel included multiple purported IACP "Training Keys" in the Fifth Amended Complaint that later could not be verified and were conceded to be the product of unverified AI-augmented research (AI hallucinations). Defendant moved for Rule 11 sanctions; the Court denied the motion on procedural grounds because the safe-harbor service requirement was not satisfied. The Court found counsel’s reliance on unverified AI-generated material irresponsible, denied sanctions, and recommended referral of the signing attorneys to the Ad Hoc Committee for potential disciplinary review.

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/2948/James_v._Conley_USA_27_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).