Fabricated — does not exist
Shaboon v. Egyptair does not exist — a fabricated AI citation
Cited as: 2013 IL App (1st) 111279-U
This case is fabricated
“Shaboon v. Egyptair,” cited to an Illinois Appellate Court unpublished-order number, is the second of the six fabricated airline-liability decisions ChatGPT produced for attorney Steven Schwartz's opposition brief in Mata v. Avianca. No such disposition exists under that docket designation; the number itself does not correspond to any Illinois appellate filing in the relevant year.
What made this and its five companion citations dangerous rather than merely wrong is presentation: each carried a superficially correct citation format — court abbreviation, year, docket-style number — the exact texture a tired associate skimming a research memo late at night would not think twice about. Judge Castel's May 4, 2023 sanctions opinion in Mata singled this pattern out, holding that the attorneys' failure to open and read a single one of the underlying “cases” before filing them was itself sanctionable, independent of whether the AI tool or the lawyer bore more blame for the fabrication. Unpublished-order citations like this one are a particular verification blind spot, since some jurisdictions genuinely restrict access to older unpublished dispositions, giving a fabricated one extra cover before anyone thinks to double-check.
Shaboon does not correspond to any real Egyptair litigation reported in Illinois courts. Anyone encountering this citation in a filing, brief bank, or AI-generated memo should treat it as conclusively fake.
AI system implicated: ChatGPT.
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