Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 30, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Delaware CC, USA · 2026-09-30

Zheng Liu v. Lynk Global, Inc.

What happened

In Delaware CC, 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 brief attributed the quotation that a stockholder is entitled to inspect records themselves, rather than a summary or explanation, to Carapico; the court found that the language did not appear in Carapico or any other opinion it could locate.
False Quotes (Case Law)

The brief attributed to Saito the quotation that oral representations by management cannot substitute for requested books and records; the court found that the language did not appear in Saito or any other opinion it could locate.
Misrepresented (Legal Norm)

The brief misstated Section 220(c) as requiring the Court to order inspection once a proper purpose is shown, using “shall” instead of the statute’s “may.”
Misrepresented (Case Law)

The brief cited Noddings as recognizing verification of stockholder status as a basic proper purpose under Section 220, but the court found that Noddings did not address a Section 220 demand and concerned contract interpretation.

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

Future filings subject to GenAI certification

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/3234/Liu_v._Lynk_Global_Inc_USA_30-09-2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).