Sanction teardown · SC Arkansas, USA · 2026-02-05
Arkansas DHS v. April Ward and Minor Child Respondents
What happened
In SC Arkansas, USA, a filing relied on Copilot to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Case Law)Brief cited cases that the court could not locate; court concluded citations may be fabricated and declined to cite them.
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False Quotes (Case Law)Brief included direct quotations attributed to purported cases; court found the quoted authority could not be located and deemed the quotes likely fabricated.
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Outdated Advice (Repealed Law)Brief relied on a statute without noting the statute had changed; the statutory text did not support the proffered proposition.
Which AI tool
Copilot. 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
Report to Office of Professional Conduct and Counsel dismissal
Additional detail
Order to Show Cause is here.
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/1458/Arkansas_DHS_v._April_Ward_USA_5_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).