Sanction teardown · S.D. New York, USA · 2026-03-27

Andrea K. Tantaros v. Fox News Network, LLC, et al.

What happened

In S.D. New York, 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)
  Plaintiff cited 'Roe v. Bernabei & Katz, PLLC, 314 F. Supp. 3d 200,209 (D.D.C. 2018)' as analogous authority; Court identified this citation as inaccurate/non-existent.
• Fabricated (Case Law)
  In the sur-reply, plaintiff inaccurately cited 'Torres v. City of New York, No. 20-CV-3384, 2021 WL 3725985, at 8 (S.D.N.Y. Aug. 23, 2021)' for the proposition that words and threats can constitute actionable violence; Court marked the citation inaccurate.
• Fabricated (Legal Norm)
  Plaintiff quoted non-existent statutory language in the GMVA, asserting it 'expressly applies to' assault, sexual misconduct, sexual abuse, and other forms of gender-based violence; Court found the quoted statutory language non-existent.
• Fabricated (Case Law)
  Plaintiff cited a non-existent case 'M.D. v. New York State Off For People with Developmental Disabilities, 2023 WL 3404357, at *10 (S.D.N.Y. 2023)' to support that verbal, psychological, and physical abuse are actionable under the GMVA; Court identified it as non-existent/inaccurate.
• Fabricated (Case Law)
  In her sur-reply, plaintiff inaccurately cited 'Garcia v. Comprehensive Ctr., LLC, No. 21-CV-6945, 2022 WL 2237452, at 4-5 (S.D.N.Y. June 22, 2022)'; Court found the citation inaccurate.
• Fabricated (Legal Norm)
  Quoted non-existent statutory language attributed to the GMVA; court found the quoted language does not appear in the statute.
• Fabricated (Case Law)
  Cited a non-existent case presented as supporting that verbal, psychological, and physical abuse are actionable under the GMVA.
• False Quotes (Case Law)
  Attributed a quoted holding to Roe in support of coverage for 'harassing comments, threats, and gestures of a sexual nature'—court flagged as an inaccurate citation/quotation in the filing.
• Fabricated (Case Law)
  Cited Garcia v. Comprehensive Ctr., LLC with specific pages and holdings as support for physical and verbal acts being covered—court identified the citation as inaccurate.
• Fabricated (Case Law)
  Cited Torres v. City of New York for the proposition that words and threats can constitute actionable violence; court identified the citation as inaccurate in the filing.

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

Warning

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://reason.com/volokh/2026/03/29/former-fox-commentator-andrea-tantaross-court-filings-contained-inaccurate-citations-court-suspects-ai-hallucinations/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).