Fabricated — does not exist
Miller v. United Airlines, Inc. does not exist — a fabricated AI citation
Cited as: 174 F.3d 366 (2d Cir. 1999)
This case is fabricated
The sixth and final fabricated case from the Mata v. Avianca brief is “Miller v. United Airlines, Inc.,” attributed to the Second Circuit at 174 F.3d 366 (1999). No Second Circuit opinion exists at that volume and page under that name; the citation was invented by ChatGPT along with five others when attorney Steven Schwartz asked it for airline-liability case law.
This is one of the clearer illustrations of how a hallucinated citation can borrow real-sounding components from unrelated genuine cases without anchoring to any single one of them — the name “Miller v. United Airlines” happens to closely track a real, decades-old California Court of Appeal decision (a 1985 employment-discrimination case, not a Second Circuit tort ruling), but the fabricated citation is not that case wearing the wrong cite; it is simply invented, appellate-circuit and all.
Because “Miller” and “United Airlines” are both common enough names to appear across many genuine dockets, this entry is a useful worked example for why case names alone are never sufficient verification — the full citation, court, and year all have to resolve to one real, findable opinion, and here none of them do.
AI system implicated: ChatGPT.
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.
Miller v. United Airlines, Inc.
174 Cal. App. 3d 878 (Cal. Ct. App. 1985) · California Court of Appeal, Sixth District · June 21, 1985
A real employment-discrimination decision that happens to share this exact case name — but it is a 1985 California state appellate ruling, not a 1999 Second Circuit opinion, and the citation format (Cal. App. 3d) does not match the fabricated 174 F.3d 366 cite at all. Do not confuse the two.
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
Mata v. Avianca, Inc.
U.S. District Court, S.D.N.Y. (Hon. P. Kevin Castel) · New York (federal) · June 22, 2023
- Outcome
- Rule 11 sanctions; letters of notice ordered to each judge falsely named as the fabricated opinions' author
- Monetary penalty
- $5,000, joint and several, paid into the court registry
- Attorney(s)
- Steven A. Schwartz and Peter LoDuca (Levidow, Levidow & Oberman, P.C.)
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Layer 1–2 check (existence + quote match) against primary sources. Not legal advice.
Related resources
More fabricated citations
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