Estate of Durden v. KLM Royal Dutch Airlines does not exist — a fabricated AI citation

“Estate of Durden v. KLM Royal Dutch Airlines” carries the trappings of a genuine wrongful-death appeal — an estate as plaintiff, a foreign air carrier as defendant, a Georgia intermediate-appellate citation format — but no such WL entry exists and no Georgia Court of Appeals panel issued this decision on the date given or any other. It is the fifth of six cases ChatGPT invented for the Mata v. Avianca brief.

This fake citation is notable because “Estate of” captions are common in real aviation wrongful-death litigation, which is likely why the model generated one — large language models trained on real legal text learn the statistical shape of a plausible airline-liability caption without any underlying commitment to whether a specific instance is real. That is the mechanism behind every entry in this set: the output is stylistically indistinguishable from genuine case law and substantively empty.

The case surfaced in the same May 2023 sanctions proceeding as its five companions, after opposing counsel and then the court itself were unable to locate it in any legal database, prompting the show-cause order that produced Judge Castel's widely cited opinion. Two years on, Mata v. Avianca remains the reference point nearly every subsequent AI-hallucination sanctions opinion cites in its opening paragraphs, including several of the more recent rulings documented elsewhere in this database.