Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 28, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · D. Connecticut, USA · 2026-09-28

Williams v. Federal Aviation Administration et al.

What happened

In D. Connecticut, 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:

Misrepresented (Case Law)

Plaintiff quoted language about a litigant retaining standing after an agency decision allegedly from Axon Enterprise and cited Laidlaw. The Court found that neither the quotation nor the cited Laidlaw passage appeared in Axon Enterprise.
False Quotes (Case Law)

Plaintiff attributed language concerning challenges to “the very framework of an agency’s operations,” claims being “inescapably intertwined” with merits orders, and injury from being subjected to a defective framework to Axon Enterprise. The Court found none of the quoted language in the opinion.
Misrepresented (Case Law)

Plaintiff summarized Free Enterprise Fund as holding that plaintiffs challenging an agency’s constitutional structure have standing based on the structural defect itself. The Court found no such holding in the case and explained that the plaintiff there had standing for other reasons.
False Quotes (Case Law)

Plaintiff attributed the quoted structural-system language to McCarthy v. Madigan. The Court found that the phrase “the constitutionality of the system itself” does not appear in McCarthy.
False Quotes (Legal Norm)

Plaintiff alleged that Section 319 required the FAA Administrator to ensure that an adequate number of designated pilot examiners were deployed. The Court found that this purported statutory quotation does not appear in Section 319, which instead requires recommendations and permits the Administrator to take such action as deemed appropriate.
False Quotes (Exhibits & Submissions)

Plaintiff claimed Defendants argued that the Court lacked subject-matter jurisdiction because administrative processes remained under appellate review. The Court reviewed the motion and found that the quoted language did not appear in Defendants’ motion to dismiss.

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/3172/Williams_v._FAA_USA_28_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).