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 · E.D. Pennsylvania, USA · 2026-09-18

Whitfield v. Prime Agency

What happened

In E.D. Pennsylvania, 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:

False Quotes (Case Law)

The filing attributed the quotation that there was no standing for wasted time and annoyance from a fax to Mauthe. The Court found that Mauthe contained no such quotation and did not address Article III standing.
Fabricated (Case Law)

The cited Wilson decision and Westlaw number could not be identified. The Court found that 2022 WL 17152188 did not correspond to an existing case supporting the asserted standing proposition.
Misrepresented (Case Law)

The cited Smith decision was misrepresented. The Westlaw number referred to a different case, and the actual Smith v. Vision Solar decision identified by the Court did not hold that two calls were facially insufficient to establish concrete harm.
False Quotes (Case Law)

The filing attributed to Foman the quotation that the pleading philosophy of the Rules affords a party an opportunity to test a claim on the merits. The Court found that this quotation was entirely absent from Foman.
Fabricated (Case Law)

The filing attributed the one-call intrusion-upon-seclusion proposition to Samuel v. U.S. Bank, but the cited Westlaw number did not correspond to an existing case and no matching Eastern District of Pennsylvania case could be identified.
Misrepresented (Case Law)

The filing stated that Gadelhak found multiple unwanted texts insufficient to constitute intrusion-type harm. The Court found that Gadelhak held the opposite: unwanted text messages can constitute a concrete injury in fact.
False Quotes (Case Law)

The filing presented an altered version of language from Foman as a quotation. The Court explained that Foman instead stated that a plaintiff should be afforded an opportunity to test a claim on the merits if the underlying facts or circumstances may be a proper subject of relief.
Misrepresented (Case Law)

The filing described Foman as a Third Circuit decision, but the Court noted that it is a decision of the United States Supreme 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

Order to Show Cause

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/3107/Whitfield_v._Prime_Agency_USA_18_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).