What was hallucinated

Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination. || Fabricated: Case Law | Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.

Details

AI UseAlim Al-Hamim, appearing pro se (self-represented), used a generative AI tool to prepare his opening brief appealing the dismissal of his claims against his landlords. He had also submitted a document with fabricated citations in the lower court.Hallucination DetailsThe appellate brief contained eight fictitious case citations alongside legitimate ones. The court could not locate the cases and issued an order to show cause.Ruling/SanctionAl-Hamim admitted relying on AI, confirmed the citations were hallucinations, stated he failed to inspect the brief, apologized, and accepted responsibility. The court affirmed the dismissal of his claims on the merits. While finding his submission violated Colorado Appellate Rules (C.A.R. 28(a)(7)(B)), the court exercised its discretion and declined to impose sanctions.Key Judicial ReasoningFactors against sanctions included Al-Hamim's pro se status, his contrition, lack of prior appellate violations, the absence of published Colorado precedent on sanctions for this issue, and the fact that opposing counsel did not raise the issue or request sanctions. However, the court issued a clear and strong warning to "the bar, and self-represented litigants" that future filings containing AI-generated hallucinations "may result in sanctions". The court emphasized the need for diligence, regardless of representation status.

Sanction teardown · Colorado, USA · 2024-12-26

Al-Hamim v. Star Hearthstone

What happened

In Colorado, 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:

Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.
Fabricated (Case Law)

Appellant cited a non-existent case; the court could not locate it and appellant later admitted it was a GAI hallucination.

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

No Sanction (due to pro se, contrition, etc.); Warning of future sanctions.

Additional detail

AI UseAlim Al-Hamim, appearing pro se (self-represented), used a generative AI tool to prepare his opening brief appealing the dismissal of his claims against his landlords. He had also submitted a document with fabricated citations in the lower court.Hallucination DetailsThe appellate brief contained eight fictitious case citations alongside legitimate ones. The court could not locate the cases and issued an order to show cause.Ruling/SanctionAl-Hamim admitted relying on AI, confirmed the citations were hallucinations, stated he failed to inspect the brief, apologized, and accepted responsibility. The court affirmed the dismissal of his claims on the merits. While finding his submission violated Colorado Appellate Rules (C.A.R. 28(a)(7)(B)), the court exercised its discretion and declined to impose sanctions.Key Judicial ReasoningFactors against sanctions included Al-Hamim's pro se status, his contrition, lack of prior appellate violations, the absence of published Colorado precedent on sanctions for this issue, and the fact that opposing counsel did not raise the issue or request sanctions. However, the court issued a clear and strong warning to "the bar, and self-represented litigants" that future filings containing AI-generated hallucinations "may result in sanctions". The court emphasized the need for diligence, regardless of representation status.

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.coloradojudicial.gov/system/files/opinions-2024-12/24CA0190-PD.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).