Fabricated — does not exist
Ex parte Holloway does not exist — a fabricated AI citation
Cited as: 992 So. 2d 521, 524 (Ala. 2008)
This case is fabricated
A mandamus petition in Ex parte A.I.F.-H. f/k/a A.I.F. cited “Ex parte Holloway, 992 So. 2d 521, 524 (Ala. 2008)” as authority. Judge Bowden's dissent in the underlying Alabama appellate ruling identified the citation as fabricated: the reporter volume and page actually correspond to an unrelated Louisiana decision, and no Alabama Supreme Court case exists at that specific citation.
The same mandamus petition also quoted a passage attributed to a real case, Ex parte Siderius, 144 So. 3d 319 (Ala. 2013) — a quotation the dissent found does not appear anywhere in that actual opinion. Bowden argued the petition should have been dismissed outright for Rule 21 noncompliance and warned generally about the waste and unreliability AI hallucinations introduce into appellate practice; the majority nonetheless resolved the underlying jurisdictional questions on the merits and granted mandamus in part, without imposing sanctions.
“Holloway” is a genuinely common Alabama-appellate surname — the Alabama Supreme Court has decided multiple real cases styled Ex parte Holloway over the years, just not one matching this specific volume, page, and year. That overlap is exactly the trap: a case name search alone will turn up real Alabama Holloway rulings and can make a fabricated citation feel half-confirmed when it isn't.
Real cases with similar names
Verified against the CourtListener case-law database. These are real, existing decisions — do not confuse them with the fabricated citation above.
Ex parte Holloway
267 So. 3d 837 (Ala. 2017) · Supreme Court of Alabama · September 15, 2017
A real Alabama Supreme Court case under the same caption, decided nearly a decade after the fabricated 2008 citation and reported at a completely different volume and page. Alabama has more than one genuine “Ex parte Holloway” on the books — none of them match 992 So. 2d 521.
Ex parte Holloway
251 So. 3d 19 (Ala. 2017) · Supreme Court of Alabama · May 12, 2017
A second, distinct real Alabama Supreme Court ruling under this same caption — again, not the case cited in the petition.
How to verify a case citation
A citation is only as good as its weakest link: the case has to exist, the quote attributed to it has to actually appear in the opinion, and the opinion has to actually support the proposition it's cited for. Deterministic verification checks each of those three things against a primary source — a real court docket or reporter, not another AI's guess — so the result does not depend on whether the tool doing the checking might itself hallucinate. That is the only way to catch a fabricated citation like this one before it reaches a filing rather than after a judge does.
Verify a citation free →Cited in these real sanctions cases
Ex parte A.I.F.-H. f/k/a A.I.F.
Court of Civil Appeals of Alabama · Alabama · June 26, 2026
- Outcome
- Noted in dissent; majority resolved the petition on the merits without imposing sanctions
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Layer 1–2 check (existence + quote match) against primary sources. Not legal advice.
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This entry documents a fabricated citation identified in a real, publicly reported court ruling. It is informational only, not legal advice. Corrections: /contact.
Written by the Citation Safe Research Desk · Reviewed by Andy Gaber, Founder