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Andria Borsody v. Frontier Heritage Communities

Court
10th Cir. CA
Jurisdiction
USA
Decided
2026-06-15
AI tool
Implied
Outcome
Admonishment
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Pro se plaintiff cited a non-existent case in briefing; the district court confirmed the case does not exist and admonished reliance on AI-generated citations.

Details

The pro se plaintiff cited 'Alford v. City of Canon City, 2019 WL 13202842 (D. Colo. Mar. 29, 2019)' in support of her position. Defense counsel reported being unable to locate the case, and the district court confirmed the case does not exist, admonishing the plaintiff for relying on generative AI without verifying citations. While the plaintiff continued to assert that the case was real, the Tenth Circuit affirmed the dismissal and the district court's caution.

Sanction teardown · 10th Cir. CA, USA · 2026-06-15

Andria Borsody v. Frontier Heritage Communities

What happened

In 10th Cir. CA, 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)
    Pro se plaintiff cited a non-existent case in briefing; the district court confirmed the case does not exist and admonished reliance on AI-generated citations.

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

Admonishment

Additional detail

The pro se plaintiff cited 'Alford v. City of Canon City, 2019 WL 13202842 (D. Colo. Mar. 29, 2019)' in support of her position. Defense counsel reported being unable to locate the case, and the district court confirmed the case does not exist, admonishing the plaintiff for relying on generative AI without verifying citations. While the plaintiff continued to assert that the case was real, the Tenth Circuit affirmed the dismissal and the district court's caution.

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.damiencharlotin.com/documents/2573/Borsody_v._Frontier_USA_15_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2573/Borsody_v._Frontier_USA_15_June_2026.pdf

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