What was hallucinated

Fabricated: Case Law | Court found counsel included a non-existent case citation in his memorandum and ordered show-cause re sanctions. || Fabricated: Case Law | Court found counsel included a non-existent (or incorrectly cited) Risucci decision; plaintiffs located a differently cited Risucci case that did not contain the quoted language. || Fabricated: Case Law | Defendant's memorandum cited a non-existent case 'Kennedy v Kennedy, 192 AD3d 111 (1st Dept 2020)'; court found the case does not exist and ordered counsel to show cause why he should not be sanctioned. || False Quotes: Case Law | Defendant's brief cited 'Risucci v Homayoon, 122 AD3d 700 (2nd Dept 2014)' and quoted language; plaintiffs located a differently cited Risucci (122 AD2d 260 (2d Dept 1986)) and the quoted language does not appear in that opinion, indicating a false quotation or misrepresentation.

Sanction teardown · SC New York, USA · 2026-02-09

Ave. Capital Group, LLC v. Strum

What happened

In SC 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)

Court found counsel included a non-existent case citation in his memorandum and ordered show-cause re sanctions.
Fabricated (Case Law)

Court found counsel included a non-existent (or incorrectly cited) Risucci decision; plaintiffs located a differently cited Risucci case that did not contain the quoted language.
Fabricated (Case Law)

Defendant's memorandum cited a non-existent case 'Kennedy v Kennedy, 192 AD3d 111 (1st Dept 2020)'; court found the case does not exist and ordered counsel to show cause why he should not be sanctioned.
False Quotes (Case Law)

Defendant's brief cited 'Risucci v Homayoon, 122 AD3d 700 (2nd Dept 2014)' and quoted language; plaintiffs located a differently cited Risucci (122 AD2d 260 (2d Dept 1986)) and the quoted language does not appear in that opinion, indicating a false quotation or misrepresentation.

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

Order to Show Cause

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/2335/08_-_Ave_Capital_Group_LLC_v_Strum.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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